U.S.-Canada Corporate Tax Challenges With Surge in Cross Border Deals, More Aggressive Enforcement, FATCA Effective
Recording of a 110-minute CPE/CLE webinar with Q&A
This webinar will provide tax professionals and counsel with a review, by an experienced panel of Canadian tax advisor/attorneys, of key recent and emerging corporate tax developments for U.S. companies. The panel will outline areas where U.S. and Canadian businesses must update tax compliance and planning.
Outline
- FATCA and new Canada–United States IGA
- Highlights of the IGA
- New Canadian implementing legislation
- Draft CRA guidance
- Transfer pricing issues for U.S. companies
- New CRA initiatives
- Recent court rulings
- Change to Canada’s Thin Capitalization Rules
- Extension to trusts, partnerships and branches
- Deemed dividend treatment of disallowed interest
- New budget proposals and implications for financing Canadian subsidiaries
- New Anti-Treaty Shopping Rule
- Implications for inbound investment
- Impact on U.S. companies
- Comparison with similar international proposals (e.g. BEPS initiative)
Benefits
The panel will address the tax implications and potential pitfalls arising from new Canadian tax developments, including:
- The Canada-United States IGA
- New transfer pricing cases and initiatives
- Updates to Canada’s thin capitalization regime affecting U.S. companies and their Canadian subsidiaries
- The anti-treaty shopping proposals contained in the last budget
Faculty
Jonathan Garbutt
Barrister and Solicitor
Garbutt Tax Law
Mr. Garbutt's practice covers general tax planning and tax minimization, M&A tax matters, international... | Read More
Mr. Garbutt's practice covers general tax planning and tax minimization, M&A tax matters, international private investment and tax controversy and litigation, transfer pricing, and Canadian trusts and estates law. He previously worked with Baker & McKenzie in Toronto.
CloseCarl Irvine
Principal
McMillan
Mr. Irvine provides advice to both Canadian and foreign clients on all aspects of domestic and international tax... | Read More
Mr. Irvine provides advice to both Canadian and foreign clients on all aspects of domestic and international tax planning, compliance and dispute resolution. He assists clients in structuring domestic and international commercial acquisitions, divestitures, reorganizations and business combinations. Mr. Irvine also regularly advises investment funds and asset managers on the establishment and administration of tax-efficient investment vehicles.
CloseMichel M. Ranger
Tax Partner
McMillan
Mr. Ranger advises clients on a wide range of domestic and international taxation matters and has specialized... | Read More
Mr. Ranger advises clients on a wide range of domestic and international taxation matters and has specialized expertise in structuring domestic and multinational commercial acquisitions, divestitures, reorganizations, financing and business combinations. He also advises clients on the tax aspects of ongoing business operations and regularly counsels both Canadian and foreign investment funds, including REITs and pension funds, on the establishment and administration of tax-efficient investment vehicles in Canada.
Close