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- 17/05/2012
BC Unveils New Sales Tax Law
- 15/05/2012
Canada Highlights Improved Online Tax Services
- 07/05/2012
New Zealand, Canada Sign DTA
- 03/05/2012
US Issues Annual IPR Country Report
- 03/05/2012
Canada Highlights Trade Support For Manufacturing
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Canada Tax News »
Treaty Update:
Canada - Poland
23/5/2012
Canada and Poland signed a Protocol to amend the existing 1987 DTA on May 14, 2012. The Protocol in particular lowers the rates of withholding tax applicable under the treaty.
Treaty Update:
Canada - Luxembourg
10/5/2012
According to the Canadian government, Canada and Luxembourg signed a Protocol amending their 1999 DTA on May 8, 2012.
Treaty Update:
Canada - New Zealand
4/5/2012
Canada and New Zealand signed a new DTA on March 3, 2012, replacing the previous agreement dating back to 1980.
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Canada Tax Treaty Updates from TreatyPro »
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Canada Features
- Living
and Working in Canada - The Expatriate
Perspective
- By Caroline Maxwell, London
In this article, we look at a
variety of issues relevant to expatriates
living and working in Canada, including
immigration, residence, and taxation.
- Doing
Business in Canada
- By Amanda Banks, London
In this article we look at the
different ways in which a foreign
corporation can do business in Canada,
and examine the advantages, disadvantages,
and taxation implications of each.
- Outward
Investment from Canada - The Offshore
Perspective
- By Caroline Maxwell, London
In this article we look at ways
in which Canadian corporations can
use an offshore subsidiary to achieve
tax efficiency, and examine the suitability
of two preferred jurisdictions in
the light of recent events.
- Income
Tax Implications for Non-Residents
Investing in Canadian Real Estate
- By Michael I Atlas, CA, CPA, TEP
This primer distinguishes between
business and non-business tax treatment
of income from real estate investments
by non-residents in Canada.
- Investment
In Canada More Attactive for Non-Residents,
contributed by Michael Atlas Chartered
Accountant.
- Canada-A
Tax Friendly Destination For Wealthy
Immigrants, contributed by Michael
Atlas Chartered Accountant.
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| Topic:
Canada |
| Bg/Sblc for lease |
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What exactly do you need?
How long do you need it for?
Are you a principal borrower or a broker? Mr. James Fisher |
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| Topic:
Canada |
| moving |
Hi, I got a job offer for abroad, my family will be staying in Canada, not sure they will follow. I have an RRSP and a Pension plan. I, do not wish to close my bank accounts, because I will be visiting from time to time. I read on the CRA website about DEEMED NON-RESIDENT, where even if someone have factual ties in Canada, however he resides in another country with which there is a Tax Treaty, the person will be considered a NON-RESIDENT for Tax purposes. what will happen to my RRSP and pension, will there be a tax of 25%? and can anyone confirm the DEEMED NON-RESIDENT issue
Does anyone has suggestions, Thanks mk |
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| Topic:
Canada |
| Offshore for Canadians |
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. Dieffenbaker |
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| Topic:
Canada |
| Holding Company Bennefits |
|
I own three residentail properties which are being rented and gennerated positive cash flow which I claim personnally. Is there a better way to shelter this investment against taxes. Should I be starting a Property Management business or Holding Company ???? Bob Needs Help |
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| Topic:
Canada |
| Offshore company formation for internet based business? |
Hello,
I am a canadian expat now working abroad in the engineering field. I have residency in Indonesia and the UAE. I also have bank accounts in Singapore, Dubai, and Canada. I am an entreprenuer at heart and i would love to start a new venture by setting up a web based business but i need some help and advice. I plan to generate income on a website advertising job postings, contingency recruitment fees for finding people work in my specialized field of engineering and maybe even contracting myself out independantly. I would ideally like to form a offshore IBC or LLC in a country with no tax, Zero required capital investment, one person ie (myself) to be director/shareholder and no requirement of local representation as well as being able to have the freedom of having my documents kepts anywhere in the world. I plan on moving back to Canada in the next year or two, as i am a bit of a nomad at the moment. I have no ties with Canada at the present time therefore i would not be subjected to taxation on worldwide income. But if i start generating income through my planned offshore business when i move back would i then have to fork over some of my earnings to the Canadian gov't? any tips on being able to avoid the taxman without getting into hot water? If anyone can recommend a country and business structure that is best suited for my plans i would really apprieciate it! Thanks
Cheers! |
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