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.