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Transfrontalière et internationale Services de conseils fiscaux Prix de transfert
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?
31 mai 2013
Transfrontalière et internationale Services de conseils fiscaux Prix de transfert
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.
31 mai 2013
Services de conseils fiscaux
Voluntary Disclosures
There has been much discussion in recent months of tax avoidance and evasion. The March 2013 Federal Budget proposes to introduce the Stop International Tax Evasion Program, which would reward individuals (up to 15% of federal tax collected) who provide tips on significant international tax non-compliance leading to collection of outstanding federal taxes in excess of $100,000.
Kathy Byvelds 15 mai 2013
Services de conseils fiscaux
2013 Ontario Budget Commentary - May 2, 2013
Finance Minister Charles Sousa delivered Ontario’s 2013 Budget, his first as Finance Minister, on May 2, 2013. The Budget is projecting a deficit of $9.8 billion for 2012-13, $5 billion lower than projected a year ago, and increasing to $11.7 billion for 2013-14. The 2010 Budget put forward a plan to cut the deficit in half within five years and to eliminate it in eight years.
2 mai 2013
Services de conseils fiscaux
Discretionary Shares: Are they under attack?
Discretionary shares are a popular income-splitting tool for professional corporations and owner-managed corporations. They have gained popularity since the Neuman decision from the Supreme Court of Canada in 1998 (Melville Neuman v. Her Majesty the Queen). Not surprisingly, the Canada Revenue Agency (CRA) is still looking for ways to attack the use of discretionary shares.
15 avr. 2013
Services de conseils fiscaux
Canada Revenue Agency GST/HST audit activities
For small businesses (generally businesses with annual sales of less than $4 million), the CRA has implemented a new audit approach whereby, instead of combined income tax and GST/HST audits, the agency will conduct separate audits. In our experience, the CRA’s increased focus has prompted auditors to focus on GST/HST issues previously overlooked during the combined tax audits era.
28 mars 2013
Services de conseils fiscaux
Tax Changes in British Columbia and Prince Edward Island
On April 1, 2013, the following will take place: British Columbia will replace its 12% HST with a combination of the 5% GST and the province’s 7% PST; and Prince Edward Island will implement the HST at 14%, replacing the 5% GST and the province’s 10% PST.
28 mars 2013
Transfrontalière et internationale Services de conseils fiscaux Prix de transfert
2013 Federal Budget Commentary: “Jobs, Growth and Long-Term Prosperity” - March 21, 2013
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.
22 mars 2013
Services de conseils fiscaux Prix de transfert
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.
13 mars 2013
Transfrontalière et internationale Services de conseils fiscaux Prix de transfert
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.
28 févr. 2013
Transfrontalière et internationale Services de conseils fiscaux Prix de transfert
U.S. Tax Changes Resulting from Fiscal Cliff Legislation
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.
28 févr. 2013
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