The course offers a general overview of international inbound and outbound tax issues facing foreign corporations with operations or activities in Canada and Canadian businesses that operate internationally or are considering expansion outside of Canada.

Learn about the effective strategies to minimize tax for inbound and outbound clients and the tax implications of cross-border transactions (e.g. foreign corporations doing business or investing in Canada; Canadians doing business or investing overseas; and transactions between members of multinational corporate groups). It will also cover issues concerning international tax treaties and international tax avoidance (and evasion).

Learn about the tax compliance requirements such Branch tax, T1134 – Foreign affiliate reporting, T106 – Reporting transactions with related non-residents.

TOPICS INCLUDE:

• Setting up a business operation in Canada – Branch vs. Subsidiary
• Cross Border Financing and related tax implications
• Strategies to repatriate profits – Return of Capital, Loans, Dividend or Management Fee
• Inter-company transactions and Loans outstanding to related non-resident corporations
• Introduction to Taxation of Foreign Affiliate – Basics, Surplus pools and FAPI
• Overview of Upstream Loans and Foreign Affiliate Dumping Rules

WHO WILL BENEFIT:

This seminar is designed for Tax professionals who: would like a comprehensive overview of Canada’s international tax system; advise corporations on cross-border taxation issues; provide services to the cross-border client; work at a Canadian or foreign multinational company as a tax manager or director; or work in a government setting that deals with international tax for Canadian businesses.