This course examines some of the most commonly applied international tax rules relating to cross-border investment into Canada. The course will draw parallels between international and domestic tax rules as they apply in the context of employee compensation, shareholder loans, shareholder financing, inter-company charges, corporate distributions, and corporate acquisitions. The Federal March 19, 2019, Budget has made these international tax concepts more relevant in the domestic – owner-manager concept.
o Tax aspects of cross-border employment/services
o Tax aspects of cross-border investment into Canada through a corporation, partnership or branch
o Thin capitalization rules
o Shareholder loan rules
o Foreign-affiliate dumping rules
o Transfer pricing rules
o Examples of inbound tax structures
o Planning Tips and Traps
This course will be co-presented by Nadia Rusak who is a Canadian and International tax lawyer with extensive experience in public and private M&A business reorganizations, estate planning and dispute resolution.
Manu Kakkar CPA, CA, TEP, MTAX
Manu has over 20 years of experience in taxation in both domestic and international, personal and corporate taxation as well as litigation support. He runs his own independent tax practice with offices in Montreal and Toronto, serving a diverse client base which includes manufacturing, retail and distribution, construction, farming, real estate, athletes and artists, across Canada and the US. His firm acts as a counsel to over 100 professional firms in Canada and USA specializing in domestic and international reorganizations and transactions. Manu is known as one of the leading experts in Section 55 of the Act and butterfly reorganizations.