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The Federal Government 2024 Budget:

Modifications to the Capital Gains Tax The Federal Government has announced the 2024 budget (“budget”) on Tuesday, April 16, 2024, and many Canadian entrepreneurs, and investors...
Apr 2024
Article

Avoiding Canadian Tax when Licensing Software into Canada

When software companies license or “sell” into Canada from abroad, there is often some leeway in how they allocate their fees between the ...
Feb 2024
Article

Investing in U.S. LLCs: The Canadian Perspective

Canadians investing in the U.S. are frequently asked do so through U.S. limited liability companies (LLCs). Unfortunately, while this structure works ...
Jul 2023
Article

Buying and Funding Canadian Companies: The Foreign Buyer’s Perspective

As a foreign purchaser of Canadian shares or business assets, simple steps may be taken today to reduce consequent costs tomorrow. Looking ahead pays ...
Jul 2023
Article

Minimizing the Income Tax Consequences of Sending Employees to Canada

When a foreign employer sends its employees to Canada, that employer must consider its own income tax position as well as that of its employees. The f...
Jul 2023
Article

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
Article

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
Article

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
Article

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
Article

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
Article

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
Article

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
Article

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
Article

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
Article

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
Article

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
Article

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
Article

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
Article

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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