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Canadian Taxation of Non-Resident Employees

Multinational business requires multinational tax planning, for employees as well as employers. When sending employees abroad, it is generally up to t...
Apr 2014

Taxing Virtual Money: The Bitcoin and the CRA

New business remains subject to the old taxes. Believing otherwise is wishful thinking. The latest tax topic in the world of technology is the Bitcoin...
Feb 2014

Canadian and Ontario Film and Television Tax Credits

View the chart here: Canadian and Ontario Film and Television Tax Credits (Chart)   Patrick is a corporate/commercial and tax lawyer of more than...
Oct 2013

Animation Outsourcing and the Ontario Computer Animation and Special Effects Tax Credit (OCASE)

Tax credits represent one of the most confusing aspects of operating an animation production company; and, within the morass of jargon, rules and pape...
Jul 2013

The Taxation of IP in a Nutshell

The tax aspects of holding, selling and licensing intellectual property may appear at first instance to be a confusion of rules further obscured by th...
Mar 2013

The New FAD: Canada’s Foreign Affiliate Dumping Rules in a Nutshell

Much of a detailed and technical nature has been written about the new so-called Foreign Affiliate Dumping Rules. But what, in plain English, are thes...
Nov 2012

Avoiding GST on the Importation of Software

A non-resident who sells software into Canada may be required to levy Canada’s Goods and Services Tax (“GST”—Canada’s VA...
Aug 2012

Canadian Principal Residence Designations by Non-Residents of Canada

Canada’s exemption from tax on the sale of a principal residence is not just for Canadian residents. Non-residents of Canada enjoy one year of t...
Jun 2012

Canada: The New Thin-Cap: Lenders Take Heed!

Canada's thin-capitalization rule has changed. Intra-group loans into Canada must be reviewed if adverse tax consequences are to be avo...
May 2012

Selling Canadian Assets: When are s. 116 certificates Wanted and How are they Had?

Non-residents of Canada who sell Canadian assets must determine whether such sale gives rise to a Canadian tax liability. If it does, it is important ...
May 2012

Canada’s Federal Sales Tax—An Overview for Non-Resident Suppliers

Those who sell goods or services in Canada have always to consider whether to become a ‘registrant’ under Canada’s federal Excise Ta...
May 2012

The Life and Times of Canada’s ULC

The Origin ... The unlimited liability company is an archaic form of corporation tracing its origins back to the United Kingdom’s Companies Act...
Apr 2012

Structuring Entry Into the Canadian Market: A Corporate Tax Primer

It is critical for non-residents to obtain proper Canadian legal advice respecting their long-term tax position before entering the Canadian market. T...
Jan 2012

Copthorne and the GAAR

The Supreme Court of Canada has issued its latest ruling on the application of the General Anti-Avoidance Rule (the “GAAR”). This decision...
Dec 2011
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