1. Navigating through the CRA On-Line portals and setting up your “Online CRA Business Account” – necessary to deal efficiently and effectively deal with the Canada Revenue Agency
2. Tax minimization – Global
3. Loss utilization
4. Transfer Pricing
5. Clearance certificates to avoid withhold for “Treaty Protected Activities”
1. Navigating through the CRA On-Line portals and setting up your “Online CRA Business Account” – necessary to deal efficiently and effectively deal with the Canada Revenue Agency
2. Tax minimization – Global
3. Loss utilization
4. Transfer Pricing
5. Canadian Research and Development tax Credits
6. Clearance certificates to avoid withhold for “Treaty Protected Activities”
a. Live performances
b. Services performed in Canada by US Corps
c. Certain construction activities
7. Mergers and Acquisitions
a. Tax efficient structures
b. Tax efficient financing
c. Tax deferred reorganizations
8. Avoid Canada and US Traps and Pitfalls
a. Misunderstood differences between Canadian and US Taxation:
i. Rental income earned by non-residents
ii. Paid-in-capital
iii. US LLC’s
iv. 351 Reorganizations (In Canada ITA Section 85 rollovers)
