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Indirect tax
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Private sector consulting
Navigating trade uncertainty: Tax planning and transfer pricing strategies
Proposed U.S. tariffs on Canadian imports create uncertainty. Businesses must adapt supply chains, tax strategies, and operations to mitigate risks. We offer expert guidance.
Scott Dupuis
Dec 12, 2024
Alert
Audit and assurance
International
Transfer pricing
Bring it back - Repatriating profits from Canada to the U.S.
In our latest Tax Alert, we explore repatriation planning, focusing on the most effective tax strategies for a Canadian subsidiary to repatriate profits to its U.S. parent corporation.
Mandeep Gaheer
Sep 12, 2023
Transfer pricing
A guide to transfer pricing
The complicated world of transfer pricing just got easier to understand. Our new specialty transfer pricing service helps businesses navigate this complex area of corporate tax.
May 26, 2023
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International
Tax advisory
Transfer pricing
Financing a U.S. Subsidiary: Debt vs. Equity
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
International
Tax advisory
Transfer pricing
Our American Customers: the Watchdogs of the U.S. Tax System
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.
May 31, 2013
Tax advisory
Transfer pricing
Transfer Pricing: the T106 Form and Related Penalties
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.
Mar 13, 2013
International
Tax advisory
Transfer pricing
U.S. Tax Treatment of Certain Canadian Tax-Deferred Accounts
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.
Feb 28, 2013
International
Tax advisory
Transfer pricing
Cross Border and International Tax Planning
Dec 21, 2010
International
Tax advisory
Transfer pricing
U.S. Estate Tax Issues for Canadians
Apr 14, 2009
International
Tax advisory
Transfer pricing
Amendments to the Canada-US tax treaty
The fifth Protocol to the Canada-US Income Tax Convention was signed on September 21, 2007, and is anticipated to come into force in early 2008. With certain exceptions, the amendments will take effect for taxable years commencing after the calendar year in which the Protocol comes into force.
Oct 17, 2007
International
Tax advisory
Transfer pricing
Canadians owning U.S. real estate
A growing number of Canadians own rental property or personal real estate in the United States. Such owners should ensure they are aware of the applicable US income tax requirements. Taking steps to understand and comply with these US tax rules could result in significant US income tax savings and avoidance of penalties and interest.
Oct 17, 2007
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