September 12, 2023 by Mandeep Gaheer
In our latest Tax Alert, we take a look at repatriation planning. Specifically, we examine the most effective tax strategies for a Canadian subsidiary (“CanCo”) to repatriate profits to its U.S. parent corporation (“USCo”).
July 26, 2023 by Mike Hayward, Dean Morris
At Baker Tilly Canada, we are committed to helping ensure fairness and integrity in the Canadian tax system.
As part of this commitment, we are grateful for the opportunity to provide our input on the Department of Finance consultation paper regarding reform and modernization of Canada’s transfer pricing rules.
May 25, 2023 by Dean Morris
Much like large global companies, small‑ to medium‑sized enterprise multinational enterprises (MNEs) may be subject to complex transfer pricing requirements. As governments increasingly seek to protect their tax base, our new Tax Alert focuses on the transfer pricing challenges and considerations facing small‑ to medium‑sized enterprise MNEs.
March 2, 2018 by Denver Nicklas
In Canada, qualified farmland can be transferred from one generation to the next for any dollar amount between cost and fair market value (FMV) at the time of the transfer. Any capital gain triggered by the transfer is covered by the capital gains exemption (up to $1,000,000 for farmland), assuming the land is qualified farm property.
May 11, 2017 by Stephen Rupnarain
This information is current to May 11, 2017. Please refer here for an updated version of this Tax Flash.
As proposed in the March 22, 2017 budget, every professional must include year-end work-in-progress (WIP) into taxable income effective for taxation years beginning after March 21, 2017. WIP for professionals typically represents unbilled professional time and cost incurred in the rendering of services to clients. This is often captured in the form of a professional’s “charge-out” rate, which represents their cost, overhead and some profit component.
April 26, 2017 by Craig Cross
The timing of revenue recognition may need to change in the near term for a construction entity preparing IFRS financial statements. Specific accounting guidance on construction contracts contained in IAS 11 Construction Contracts is replaced effective for annual reporting periods beginning on or after January 1, 2018. The International Accounting Standards Board (IASB) has published a new standard, IFRS 15 Revenue from Contracts with Customers (IFRS 15). IFRS 15 sets out requirements for recognizing revenue that apply to all contracts with customers.
June 8, 2016 by David Kemp
It seems that every day now there is an article of some sort addressing aggressive tax structures, often utilizing offshore entities, and the ramifications of (implied) inappropriate, underlying transfer pricing policies. Recently, this has clearly been due to the news of the “Panama Papers” disclosure or, more generally over the past couple of years, the result of the recently finalized Base Erosion and Profit Shifting Project reforms published by the Organisation for Economic Co-operation and Development.
Canadian corporations seeking to expand their operations often look southward to grow their business. By expanding into the United States, Canadian corporations can potentially gain access to a much larger market than is available in Canada. For a variety of valid reasons, Canadian corporations often choose a U.S. corporation as a vehicle for expansion into the U.S. But once this structural decision is made, the question becomes, how to finance the U.S. operations?
May 31, 2013 by John F. Oakey
With today’s technology, it is becoming increasingly easy to sell products to individuals and companies all around the world. Many Canadian companies have developed great business relationships with U.S. customers, selling a wide variety of goods.
The Honourable Jim Flaherty, Minister of Finance, today tabled Canada’s Economic Action Plan 2013, a budget focused on balancing the budget during this Parliament. This budget introduces skills training initiatives, a federal infrastructure plan and new investments to support manufacturing and innovation in Canada.
March 13, 2013 by David Kemp
The T106 Summary and corresponding Slips (collectively, the T106 Form) represent the annual information return used to report non-arm’s length transactions between reporting persons or partnerships and non-residents, in accordance with section 233.1 of the Income Tax Act.
While many U.S. citizens living in Canada have recently become aware of the requirement to file annual U.S. individual income tax returns, they may not be aware of the specific filing requirements in regard to certain registered investment plans held in Canada.
On January 1, 2013, the long-anticipated American Taxpayer Relief Act of 2012, commonly known as the Fiscal Cliff Legislation (FCL), was passed into law. The FCL addressed looming reversions to old tax rules that could have affected up to 98% of American taxpayers.
In what has become a recurring topic over the last two years, the U.S. Internal Revenue Service (IRS) announced new streamlined filing compliance procedures to allow U.S. taxpayers living outside of the U.S. to come into compliance with their U.S. income tax and related filing obligations. The announcement was made...
On June 22, 2012, the IRS announced interim changes to the Individual Taxpayer Identification Number (ITIN) application process. What is an ITIN? An ITIN is a tax processing number issued by the IRS to individuals who are required to have a US taxpayer identification number but who do not have,...
President Obama's recent initiatives to grow the U.S. economy have been premised on removing the hurdles to unlocking America's innovation and creativity. The "We Can't Wait" initiative, which liberalizes visa procedures to increase travel and tourism in the U.S., will pump money into the U.S. economy and, ideally, will create...
The Fifth Protocol of the Canada-U.S. Tax Convention (the Treaty) introduced new anti-hybrid rules in Article IV(7) intended to deny Treaty benefits for amounts of income, profit or gains involving hybrid entities. The new rules generally operate to deem an amount of income, profit or gain to be not paid...
In this Tax Alert, we review the general state of U.S. tax affairs in Washington as 2011 drew to a close, and highlight the transition of the voluntary tax filing initiatives for non-compliant U.S. tax filers from the 2011 Offshore Voluntary Disclosure Initiative (OVDI) program to the 2012 Voluntary Disclosure...
On Monday, December 13th, 2011, the Internal Revenue Service ("IRS") issued prospective guidance for those US persons (US citizens and green card holders) living outside the US who are not in full compliance with their US tax and foreign bank account (FBAR) filings. IRS fact sheet FS-2011-13 summarizes information about...
The U.S. Internal Revenue Service (IRS) recently announced a special voluntary disclosure initiative that should be of particular interest to U.S. citizens resident in Canada. According to the IRS press release dated February 8, 2011, the 2011 Offshore Voluntary Disclosure Program (OVDP) is "designed to bring offshore money back into...