<strong>Financing a U.S. subsidiary</strong> When a Canadian company creates a U.S.-based subsidiary, one of the first issues to be addressed is how to fund those operations. Generally, funds may be advanced in the form of equity, debt or a combination of both.

Trusts are important tools in Canadian tax and estate planning. Discretionary family trusts, in particular, have become common and are continually evolving. Some of the most powerful benefits of these tools include: <ul> <li><strong>Flexibility</strong> – the ability to maintain control of assets while directing income and value as the trustees see fit.</li> <li><strong>Income splitting</strong> – directing income of the trust to lower-income beneficiaries (usually family members) to minimize the overall family tax burden.</li> <li><strong>Capital splitting</strong> – allocating capital gains to beneficiaries, enabling the use of multiple capital gains exemptions.</li> </ul>

Canadian persons that spend significant time in the United States can become subject to U.S. taxation and reporting requirements unexpectedly, even if they are not earning income from U.S. sources.  Starting June 30th, 2014 a new initiative will begin that is designed to track a Canadian person’s movement across the Canada/U.S. border.  Prior to this new initiative, many Canadian persons felt, perhaps justifiably, that U.S. authorities had no way of actually knowing how many days they were present within their border.

As tax professionals, we are often asked by clients to explain the concept and appropriate uses of holding companies. The answer generally is not straightforward; a variety of tax and commercial factors are relevant in any particular case. Though it is beyond the scope of this article to provide a complete list of potential benefits and drawbacks, an introduction to several key issues will be examined.

Selling your farm is supposed to be tax free, right? At least the first $800,000. So why is that not always the case, and what can you do about it?

Canadian business owners can extract tax-free cash from their corporations by using innovative strategies. Explore these tax effective ways to extract cash from your business.

The deficit for the 2013-14 fiscal year is projected to be $11.3 billion, which is $400 million less than the amount estimated when the 2013 Budget was tabled. The deficit for the 2014-15 year is projected to be $12.5 billion and the longer-term forecast continues to call for a return to a surplus by 2016-17. Net public debt to GDP is projected to continue to increase until 2015-16, from which time it will to start to decrease.

This article provides information about the Voluntary Disclosure Program (VDP) administered by the Canada Revenue Agency (CRA). The VDP encourages taxpayers to come forward voluntarily to declare information that may not have been previously reported. It may be used to divulge unreported or underreported financial information. Use of this provision provides defense against penalty and prosecution.

Revenue is a good thing; we are always looking for ways to increase it. But in the GST/HST world, dividend and interest revenue can reduce income in addition to causing huge compliance costs and issues. This can come as an unwelcome surprise to many taxpayers.

I recently delivered a webinar to a group of associates at one of my law firm clients, as part of the firm’s internal CPD and training program. Among the advice I gave the associates was a recommendation to start looking for opportunities to streamline their work, increase their efficiency, and reduce their own “cost of doing business,” in order to make themselves and their practice groups more competitive and effective.

This article could equally well be called "How to prevent your competitors from stealing your clients." It's not that these other lawyers lack ethics, values and courtesy. It's just that as practices diminish, revenues have to be obtained somewhere to support the firm and its employees. The bottom line is that others may have your clients in their crosshairs. So what are you supposed to do about this? Here are seven suggestions: