Cross-Border Corporate Tax: New Challenges in US and Canada

Cross-Border Corporate Tax: New Challenges in US and Canada

Recording of a 100-minute CPE webinar with Q&A

Conducted on Tuesday, November 27, 2007

Course Materials


Canada is the U.S.' largest trading partner, so tax professionals and counsel at U.S. companies must actively monitor and understand changes in tax law and policy on both sides of the border.

For example, the US-Canada Tax Treaty is likely to be amended to phase out withholding tax on investment interest and to clarify taxation of stock options. And, while the Canada Revenue Agency works on new regs for royalties and intangibles, the IRS finalized new dual consolidated loss regulations.

Corporate tax specialists for U.S. companies must stay current on how the latest guidance, tax laws and regulations in Canada impact the cost of doing business there through corporations and partnerships or through plants and branch offices. The same is true for Canadian companies operating here.

Listen as our panel of experienced tax counsel and CPAs provide their analysis of and insights on the most recent, relevant developments in corporate tax on both sides of the US-Canada border.



The panel will discuss tax and accounting strategies on these new laws and emerging developments including:

  • Recent and proposed amendments affecting U.S. taxation of income from Canadian operations and investments - and how Canada computes taxable income and surplus.
  • Changes in how each country calculates "effectively connected" income from branches or partnerships.
  • The current status of U.S. and Canada taxation of royalties and intangible assets held by companies across the border and treatment of stock-vs.-asset acquisitions.
  • Strategies for planning for Canadian GST and consumption taxes.


Carey Singer
Carey Singer
Mintz & Partners

He is a principal in charge of the accounting firm's U.S. Tax Practice. He specializes in tax planning and return...  |  Read More

Jonathan Garbutt
Jonathan Garbutt
Baker & McKenzie

He focuses on general tax planning, tax controversy and litigation, and M&A for corporate clients.

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