Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 It is common for businesses to consider international expansion as a means to achieve growth. Given the geographic proximity of Canada and the U.S., it is logical that many Canadian businesses would consider expanding into the U.S. and vice-versa. Below are discussed […]
Tax Taxation
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Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 It is common for businesses to consider international expansion as a means to achieve growth. Given the geographic proximity of Canada and the U.S., it is logical that many Canadian businesses would consider expanding into the U.S. and vice-versa. Below are discussed […]
Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 It is common for businesses to consider international expansion as a means to achieve growth. Given the geographic proximity of Canada and the U.S., it is logical that many Canadian businesses would consider expanding into the U.S. and vice-versa. Below are discussed […]
Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 In an increasingly globalized and digitized world, small and medium-sized enterprises can grow and compete internationally to an extent that was not previously possible. These same economic realities have also forced many small and medium-sized enterprises to expand outside of Canada or […]
Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 International competitiveness is a rather ill-defined term since it could have a variety of meanings. It might mean how competitive a country might be as a place of location for investments and production compared to other jurisdictions. It could also imply how […]
Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 International competitiveness is a rather ill-defined term since it could have a variety of meanings. It might mean how competitive a country might be as a place of location for investments and production compared to other jurisdictions. It could also imply how […]
Schedule a Secure Video Conference Call on Cisco Webex ™ For Canadian Parent Corporations Considering U.S Business Investment – Analysis and Methodology – Part 2 Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 When a Canadian corporation (Canco) considers expansion into the U.S, careful consideration of key […]
Schedule a Secure Video Conference Call on Cisco Webex ™ For Canadian Parent Corporations Considering U.S Business Investment – Analysis and Methodology – Part 1 Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 When a Canadian corporation (Canco) considers expansion into the U.S, careful consideration of key […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Canadians Expanding Business To The U.S – Issues To Attend To. Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 Growing Canadian businesses searching for new markets are conducting business on a multinational level. The United States, being […]
Schedule a Secure Video Conference Call on Cisco Webex ™ U.S Business Structures for Canadian Parent Corporations Doing Cross-Border Business – Part 2 Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 Growing Canadian businesses searching for new markets are conducting business on a multinational level. The United […]
Schedule a Secure Video Conference Call on Cisco Webex ™ U.S Business Structures for Canadian Parent Corporations Doing Cross-Border Business – Part 1 Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 Growing Canadian businesses searching for new markets are conducting business on a multinational level. The United States, […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Canadian Corporations Doing Business In The U.S - Responsibilities and Expectations - Part 2 Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 Growing Canadian businesses searching for new markets are conducting business on a multinational level. The […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Canadian Corporations Doing Business In The U.S - Responsibilities and Expectations - Part 1 Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 Growing Canadian businesses searching for new markets are conducting business on a multinational level. The […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Income Characterization for Canadian Corporations Doing Business Outside Canada - Foreign Accrual Property Income (FAPI) Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 Canadian tax liability generally turns on whether a person is a resident or a […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Foreign Affiliate Issues: Understanding FAPI and Optimal Cross-border Structuring Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 FOREIGN AFFILIATE ISSUES 1. UNDERSTANDING THE CALCULATION OF FAPI 2. CROSS BORDER STRUCTURE TO REDUCE COMBINED TAX Canada and […]
Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 Individuals that receive certain types of income derived from a “related business” will be subject to Tax on Split Income (TOSI) unless an exclusion applies. TOSI is subject to the highest personal tax rate with no benefit of personal credits. Commencing on January […]
Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 A December 11, 2017 Tax Court of Canada case examined whether a taxpayer was liable for unpaid income taxes of the corporation of which he was a director. CRA’s assessment was based on the assertion that the taxpayer was a legal representative of […]
Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 In an August 14, 2019 Tax Court of Canada case, at issue was whether the sales of four properties in B.C. were on account of income (fully taxable) or capital (half taxable), and whether they were eligible for the principal residence exemption (potentially […]
Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 For an employee to deduct travel or motor vehicle expenses against employment income, the employee must be normally required to work away from the employer’s place of business, be required to pay the travel expense under the contract of employment, and have a […]
Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 A Tax Court of Canada case reviewed various deductions claimed against a taxpayer’s business income derived from engineering and arbitration services related to the business use of his home. The taxpayer and the CRA had agreed that 35.83% of the home, mainly the […]
Slide 2The Section 84 Deemed Dividend RulesWhat to do to avoid the deemed dividend trap. READ MORESlide 2Taxation Issues for Canadian Corporations with Foreign AffiliatesAn overview. READ MORESlide 2Using Joint Ventures To Capitalize On Real Estate InvestmentsResearch tax-efficient structures to facilitate real estate investing. READ MORESlide 2The Replacement Property RulesUsing […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Canada Revenue Agency Enhances Audit Activity on Real Estate Transactions Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 For those involved in Real Estate investing, the CRA is enhancing it’s audit activity around real estate transactions, presumably because any […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Using Joint Ventures To Capitalize On Real Estate Investments Joint Ventures are increasingly being used by Real Estate Investors to suitably combine financial capital with pro rated risk exposure, and the structure provides a comfortable legal and logical framework […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Section 84 And The Deemed Dividend Rules - Avoiding The Deemed Dividend Trap Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 Canada’s deemed dividend rules as found in section 84 of the Income Tax Act (ITA) are […]
Schedule a Secure Video Conference Call on Cisco Webex ™ The New Refundable Dividend Tax On Hand (RDTOH) Provisions Explained Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 As part the 2018 budget, the federal government announced two proposed measures to restrict the tax advantages of earning passive investment […]
Schedule a Secure Video Conference Call on Cisco Webex ™ An Overview of Attribution Rules Canada Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 Income splitting among family members can be beneficial largely because of the graduated tax rates used in our income tax system. All provinces […]
Schedule a Secure Video Conference Call on Cisco Webex ™ The Concept of Adjusted Aggregate Investment Income - What Does it Mean? Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 The 2018 federal Budget includes a measure designed to slow the accumulation of passive investments within active […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Taxation Issues Facing Canadian Parent Corporations With Foreign Affiliates Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 The prospect for Canadian parent corporations to invest in foreign subsidiaries can provide multiple business opportunities that otherwise may not […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Corporate Tax Planning: Utilizing The Butterfly Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 In 1981, John Robertson, then director general of the CCRA’s Corporate Rulings Directorate, presented a paper at the annual conference of the Canadian […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Tax Planning And Transfer Of Wealth Using Life Insurance Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 There has been a substantial increase by corporate and individual taxpayers alike in Canada of the use of Life Insurance […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Inter-Corporate Dividends And Subsection 55(2) - What You Need To Know. Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 Taxation of inter-corporate dividends has been expanded by amendments to Subsection 55(2) of the Income Tax Act first […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Safe Income And The Calculation Of The Safe Income Determination Time Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 Amendments to section 55(2) of the Income Tax Act (IT) greatly broadened the reach of subsection 55(2) primarily due […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Learn About the Eligibility Criteria for Using the Income Tax Act Under Replacement Property Rules Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 The purpose of the replacement property rules in the Income Tax Act (ITA) is […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Protecting Your Wealth For The Next Generation: Provisions To Transfer Wealth Efficiently. Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 If a taxpayer owns shares in a corporation that was built over the years and that now […]
Schedule a Secure Video Conference Call on Cisco Webex ™ The Foreign Accrual Property Income (FAPI) Rules. What Corporations Need To Know Before Investing Outside of Canada. Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 When a Canadian corporation holds a controlling interest in a foreign affiliate, […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Tax Planning With Estate Freezes - An Overview Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 An estate freeze is a technique used to freeze the value of someone’s business interest, pass the future growth in that […]
Schedule a Secure Video Conference Call on Cisco Webex ™ The Corporate Attribution Rules - Navigating Through The Delicate Nature Of Non-Arms Length Transactions Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 Income splitting has become a very popular technique used by many individuals for effective income tax […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Income Tax And Non-Residents - Part 2 Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 In part 1 of our article on taxation of non-resident Canadian income, we dealt with the various filing requirements non-residents must complete […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Income Tax And Non-Residents - Part 1 Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 Sections 115 and 116 of the Income Tax Act (ITA) deal with Canadian sourced income and capital gains generated on taxable Canadian […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Best Practices And Tax Planning Essentials Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 The concept of corporate and personal tax planning over the last 10 years has become more complicated as the Canada Revenue Agency (CRA) […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Amalgamation or Wind-Up - What's The Difference? Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 The Income Tax Act provides 2 main merger techniques that can be used to consolidate two or more Canadian corporations. There are […]
Schedule a Secure Video Conference Call on Cisco Webex ™ Leading Tax Advice Call Nicholas Kilpatrick 604-612-8620 Under paragraph 88(1)(d), the Income Tax Act permits an increase (or bump) in the cost of property and effectively reduces or completely eliminates accrued gains that would otherwise be […]
The Capital Gains Exemption (CGE) remains one of the most beneficial components of the Canadian tax system. Rewarding resident Canadian business owners for their contributions to the Canadian economy, the CGE allows for the exemption from tax on the first $913,630 (in 2022) gain on the sale […]
The Capital Gains Exemption (CGE) remains one of the most beneficial components of the Canadian tax system. Rewarding resident Canadian business owners for their contributions to the Canadian economy, the CGE allows for the exemption from tax the first $913,630 gain (in 2022) on the sale of shares of a […]
Sole Proprietorship vs Corporation – How to set up your business Many people considering a venture into the foray of business ownership eventually need to make a decision as to how to operate: as a sole proprietor or as a corporation. Our office fields this question quite often, […]
Enjoy the Benefits of Operating as Personal Service Corporation In Canada, utilizing a corporation to operate your business through provides substantial tax benefits over operating as a sole proprietorship. These benefits include legitimate tax minimization, income splitting, and limited asset protection from creditors. However, there are limitations to using […]