Services

• Tax planning for investments into Canada

  Tax planning for investments into Canada

  • Purchase of a Canadian business or product (license) by a non-resident of Canada.
  • Purchase of real property in Canada.
  • How to structure such acquisitions so returns to investors minimize and withholding and income taxes on revenue streams and maximize the after-tax return on a future sale of said assecing planning and documentation with respect to intra-group transactions.
• Tax controversy

  Tax controversy

  • Dealing with audits, ressessments, objections, appeals and tax litigation with Canadian tax authorities.
  • Handling voluntary disclosures & dealing with tax problems proactively.
  • Guiding non-residents of Canada through the procedures and concepts necessary for solving complex Canadian tax issues before the issues become problems.
• Canadian Tax and Trusts Structuring for Wealth Planning

  Canadian Tax and Trusts Structuring for Wealth Planning

  • Dealing with the needs of global high-net worth families including succession planning for businesses, earn-ins and earn-outs for transitions, trusts, wills and estates, especially international or offshore trusts and estates, where more than one jurisdiction is involved.
  • Global tax minimization strategies that will work, but are flexible enough to deal with changing circumstances.
• Tax-efficient Immigration to Canada

  Tax-efficient Immigration to Canada

  • Helping high-net-worth individuals and families with their transitions from living in, or being a citizen or tax resident of another country and becoming a resident and/or citizen Canada while optimizing the opportunities for tax minimization that arise on such a transition.
  • Helping high-net-worth individuals and families look at where they are resident and determine where they want to be for tax, personal safety or business reasons, and then assisting the individual or family achieve the residency, citizenship and tax outcomes sought.
• Transfer pricing

  Transfer pricing

  • Planning and documentation with respect to intra-group transactions.
  • Ensuring penalties for failure to document do not apply.
  • Optimizing opportunities for global tax minimization in an appropriate and acceptable manner.
• Scientific Research and Experimental Development (SR&ED) Planning

  Scientific Research and Experimental Development (SR&ED) Planning

  • Canada offers significant tax credits for entities that invest in research & development of new products and services in Canada.
  • Optimization of these credits requires the co-operation of a tax lawyer, accountants and SR&ED consultants specializing in such planning.
  • Optimizing opportunities for global tax minimization in an appropriate and acceptable manner.
• Tax planning for non-resident Canadian citizens and those who intend to become non-residents

  Tax planning for non-resident Canadian citizens and those who intend to become non-residents

  • Planning and advice to ensure that non-residents are really non-resident and stay that way.
  • Planning with regard to the structuring and disposition of Canadian assets in a tax-efficient manner.
  • Estate planning to deal with Canadian assets and beneficiaries in a tax efficient manner.
  • Advice and planning to minimize the Canadian "exit tax".