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March 12, 2018 by John Oakey

Taking action on passive investment rules

If you listened closely on budget day, you could hear a sigh of relief across Canada after the federal government announced new rules on passive investment income. Largely considered a fair improvement from previous iterations of the rules, many tax practitioners welcomed the changes. However, not all were pleased. And some were far from relieved.

February 16, 2017 by Bill Camden

Strategies for Dealing with the New SBD Rules

Some taxpayers utilize corporate groups, which have been structured to multiply their access to the small business deduction (SBD). The SBD allows a company to pay a lower tax rate on the first $500,000 of income each year. Access to the SBD is sometimes limited as it must be shared by associated corporations and corporate partners. To avoid having to share the SBD, some businesses that naturally work in groups, have structured their affairs in a way that allows more than one $500,000 small business deduction. In reaction to this multiplication strategy, the government introduced legislation in the 2016 federal budget to end the effectiveness of such structures and, in effect, increase tax rates for companies in such groups.

December 16, 2016

Multinational companies, minimize pesky (higher) U.S. taxes

For multinationals with branches in both Canada and the United States, there’s one big tax challenge that’s impossible to ignore: U.S. tax rates are generally higher than Canadian tax rates. Companies wrestling with this issue are always looking for ways to reduce U.S. income and maximize Canadian income (within the existing rules), lowering their overall tax burden. Some strategies include financing, transfer pricing, inter-company charges, and reducing tax liability through tax planning. To make the most of these options, it’s important to take the following steps.

August 16, 2016 by Mike Hayward

How to work outside Canada and pay taxes (or not!)

If you are a Canadian planning to work abroad, you need to find out whether your residency will change, because if it does, it may affect your Canadian tax burden. Will you remain a Canadian resident during the period of your assignment or will you break Canadian residency? When you cease to be a Canadian resident, you normally aren’t subject to Canadian tax anymore. However, if you remain a Canadian resident during your assignment, you still have to file a Canadian tax return and will be subject to taxation on your worldwide income.