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Dieffenbaker Posted on: 27/07/2010 Posted at: 23:18:52	Offshore advice for Canadians is scarce on the internet. No reporting requirement for overseas kept money below CAD 100K per natural persons. No reporting requirement for natural persons owned assets (NO LIMIT in value) provided that such assets are "of personal use", meaning a second home (you can have a second home in many a country for unquestionable reasons), boats, cars, art collections, jewels (however, precious stones and gold coins must be reported). For moderately wealthy Canadians, offshore gets more complicated and more risky when you go corporate: the Canadian Revenue Agency (CRA) will apply Common Law doctrine + far reaching and complex tax jurisprudence by which a holding vehicle will be deemed resident in Canada no matter it was incorporated outside of Canada. CRA will base their decision on where the beneficiaries are resident, where the assets are located and... where the "mind and control" is resident. Therefore, it seems that extreme attention must be given to appointing nominee directors, stating irrevocability of who can be appointed to such positions so as not to be deemed possible to change for a canadian resident as director at some point in the future, for offshore vehicles to really hold water for Canadians (I mean for Canadians other than the super-rich). Otherwise CRA will say that you may appoint yourself in the future. Multi-layer structures seem to be inevitable. Then remain the open question of how to transfer money offshore, what is private enough when it come to transfer money, etc... Promoting offshore vehicles (by local lawyers) in Canada is now discouraged, if not punishable. Voluntary disclosure has gone trendy. Private banking departments of major Canadian banks (the only ones entitled to do the promotion job) are discreet. Usually, a solution is available only through banks, for HNWI (above 1M$), banks will submit a structure proposal to some prominent law firm in order to get some sort of "green light" legal opinion as for tax compliance (can this design fly or not fly). So what you find in Canada is classical relationship between banks and major law firm, offering costly solutions for super rich but nothing for the "new rich". But even then, multiple TIEAs signed recently begin to give super wealthy Canadians some headaches (but to a much lesser extent than to American citizen because Canada is a rising empire on the map, loaded with natural ressources, with very well capitalized banks (there are only 6 banks) and less endebted folks, doesn't tax on citizenship but upon residency). The offshore question remains open for worried and overtaxed Canadians: is it better to stay under the "personal use" rule which scope is certainly wide enough for most snowbird investors. Or is it better to "go corporate". For those who need to go corporate, how and where? Any thoughts, experience, advice to share, please feel free. Canadian tax law non-competent, please abstent.
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Anonymous Posted on: 04/09/2010 Posted at: 06:31:39	I don't see your point many canadian banks have foreign branchs in aruba, turk caico, caiman, bermuda, british virgin island just to name a few. jean crétien
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Anonymous Posted on: 30/03/2012 Posted at: 19:28:30	Anonymous - if you read actually Dieffenbaker, you will know those locations you suggested will not last as new TIEAs will be signed and they would not provide old sense offshore anonymity not for long. HNWI does not take risks and they will seek out more legal solutions to defer tax than completely hide-and-not-pay.
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