We are actively involved in virtually every area of international taxation, from cross-border mergers and acquisitions, to joint ventures, spin-offs, restructurings, financings and leasing transactions.
Our clients include both public and closely held companies involved in a wide range of activities, from manufacturing, food and energy production and distribution, to securities, software, healthcare, and real estate development and management. We have helped structure venture capital and hedge funds and have advised on the acquisition, operation and disposition of a variety of public and private companies in Canada, Europe, the Middle East and Far East. We represent entertainers, athletes, corporate executives and wealthy individuals and families with assets and members in multiple jurisdictions. We work closely with foreign tax counsel to maximize overall tax-efficiency, coordinating Canadian tax rules with those of the appropriate foreign jurisdictions.
Foreign Business Activities in Canada
Our attorneys are deeply involved in all aspects of planning for foreign investors, from selecting a business vehicle, to structuring transactions and evaluating operating alternatives. Such “inbound” planning often involves avoiding the creation of a Canadian “permanent establishment,” as well as the use of derivative investments, portfolio interest, and other techniques to minimize Canadian withholding taxes. Our in-depth experience with Canadian income tax treaties includes the “tie-breaker” provisions for dual residents and the anti-abuse provisions designed to limit treaty access in circumstances where the foreign investor may be “treaty shopping” or may not be considered the beneficial owner.
We have extensive experience with the “taxable Canadian property” that apply to investments in Canadian real property by foreign investors.
We advise foreign individuals who relocate to Canada on pre-immigration tax planning, restructuring investments, and the complex reporting requirements applicable to Canadian residents with interests in foreign corporations, partnerships, trusts, and foreign financial accounts.
Canadian Business Activities Abroad
We advise Canadian clients on their international operations, from structuring cross-border activities in manufacturing, sales and financing, including currency and interest-rate swaps, to minimizing the impact of the FAPI rules. We have helped clients plan real estate and hotel developments in Europe and the Caribbean, establish factories in the Far East, incorporate offshore insurance companies, and launch foreign private equity funds.
We assist clients with the reporting requirements for interests in foreign corporations, partnerships, trusts, and foreign financial accounts.