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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
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Why Are You Growing?
Mergers are tactics that should support a law firm’s strategy. But some firms fall into the trap of using mergers as a substitute for strategy. Before you grow your firm, make sure you know what you hope to achieve.
Apr 18, 2013
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Tax advisory
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.
Apr 15, 2013
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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
385 PEOPLE
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
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Tax advisory
Interest Deductibility
At some point in the lives of most individuals and business enterprises, loan interest becomes a significant annual expenditure. Not surprisingly, its deductibility in computing income has been the subject of many disputes between taxpayers and the Canada Revenue Agency (CRA).
Feb 22, 2013
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Using partnerships in your farming business
Jan 15, 2013
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Corporate owned buildings on land owned by shareholders
Jan 10, 2013
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Public markets
Variety of capital options in Canadian public markets
Attaining and sustaining growth within the US oil and gas industry requires considerable capital. While attracting investor support within the United States may be the preferable choice, pursuing such capital within the Canadian public markets may also merit consideration.
Dec 31, 2012
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Tax advisory
Spousal Trusts as a Tax Planning Tool
The use of trusts in a will (testamentary trusts) can be a very effective tax planning tool. Such trusts can provide for income splitting even after death.
Dec 20, 2012
544 AERIAL
Before and after incorporating your farming business
Nov 22, 2012
97 AR
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