International Taxation

Globalisation, open markets, mobility...

These concepts hide major strategic challenges for corporations desiring to expand abroad. The same applies to employees accepting a foreign jurisdiction posting and wishing to optimize their net income.

As an entrepreneur, you are probably questioning yourself on the best ways to study the foreign market, the possibility of transferring employees or even relocating key employees. Perhaps you may be thinking of acquiring a foreign corporation or evaluating which is the ideal structure to successfully ensure your expansion.  

As an individual facing temporary or permanent relocation, you must determine how to minimize the fiscal and compliance costs resulting from such a decision. You may also have in your possession inheritance distributed in several jurisdictions in which case you may wonder how to structure your estate planning in order to minimize the effects of potential double taxation that may occur following your death.     

In short, we ensure you meet your personal and business fiscal obligations in the host country as well as the demands concerning sales tax, deductions, remittances, registrations and all other particularities for each fiscal jurisdiction. At the same time, we will minimize the economic burden of tax compliance of your country of residence and all other jurisdictions in which revenues or assets are generated.

As a response to these many complex challenges, we provide a personalized approach, expertise and know-how based on an in-depth understanding of the Canadian and foreign tax systems. In addition, we call upon the expertise of partners, immigration lawyers, relocation specialists, customs consultants or professionals located in the host country, to provide the best solutions and facilitate your integration abroad.

 

Areas of Expertise


Market Development Outside Quebec

  • Establishment of an action plan for each phase of your corporate development (survey new markets, presence of employees abroad and employer issues, permanent corporate structure, long-term change ok key employees, international financing)

Foreign Companies

  • Support for the Canadian implementation of foreign companies and optimisation of the local operating structure minimizing tax costs
  • Support for specific compliance

Cross-border Corporate Structure

  • Strategic planning with regards to the best corporate structure to adopt (entity type, business model, effect of tax treaties, income repatriation issues, method of financing operations, employer issues, liability to sales tax)
  • Assistance with setting up abroad (logistic)
  • Management of local compliance by foreign jurisdiction (corporate taxes, employee taxes, employer obligations, registration and sales tax rebates and local business taxes, among others)

Transfer pricing

  • Preparation and documentation for transfer pricing, prior to agreements, dispute resolution: analysis, audit defence and voluntary disclosure/competent authority.
  • International tax strategic review

Cross-border Employee Transfers

  • Personal planning relating to relocation and tax residence
  • Advice on employment contracts and compensation
  • Support in foreign compliance and taxation specific to the relocation of the country of origin
  • Integrated planning for the assignment period and in anticipation of the return to the country of origin
  • Issues for the employer (payroll, compliance requirements, relocation strategic planning, optimized compensation package)
  • Assistance with cross-border compliance and upon departures

US Income Tax Return

  • Obtaining ITIN, EIN and other identifiers
  • 1040, 1040NR, 1120, 1120-F, 1065 et K-1, 1041 and 706 series, among others
  • Streamlined procedure

Real Estate, Estate & Relocation

  • Planning the methods of acquisition, possession and disposal of foreign real estate by Canadian residents or Canadian real estate for non-residents
  • Strategic estate planning in situation cross-border assets
  • Annual compliance and support for the management of assets and rental income
  • Support to immigrants, implementation of immigration trusts and corollaries

… among others, these elements illustrating typical interventions but not being exhaustive.