International Practice

10 Tax Tips & Traps for Non-Residents with a Presence in Canada

For international businesses, cross-border investments and transactions can bring numerous uncertainties, not least of which are potential tax liabilities. My clients regularly contact me with concerns about these matters, raising questions about topics such as thin capitalization and back to back loan rules, sending employees overseas, selling real estate, repatriation of funds, and more.

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Choice of US Entity for Foreign Companies

Foreign companies (“FC”) wishing to establish a US entity to expand their business activities in the US will need to consider whether to form a corporation (Inc.) or a limited liability company (LLC).  Likewise, an FC which wants to invest in an Inc. or an LLC will need to be familiar with certain tax and non-tax aspects of an Inc. and an LLC…

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