Tax Services

International Tax

Emigration from Canada (planning and tax considerations related to the termination of Canadian residency for tax purposes)
Immigration to Canada
Transferring a foreign pension plan to Canada
Assignment of employees abroad
Compliance for foreign affiliates (Form T1134, surplus calculations, etc.)
Planning and implementation of the optimal structure
Cross-border reorganization
Strategic fiscal review
Internal transfer pricing – risk management, optimization and compliance (documentation, Form T106)

Sale of real estate by non-residents of Canada – request for certificates (T2062 and TP-1097)
Analysis of tax withholding obligations when payments are made to non-residents of Canada (services, interests, dividends, royalties, etc.).
Analysis of relevant tax treaties and preparation of documents needed to proceed with the reduction of tax withholdings, if any
Canadian tax compliance for all non-resident transactions involving non-residents (NR301, NR302, NR303, NR4, Reg. 102, Reg. 105)
Acquisition of a Canadian company by foreigners, corporate holding structure and financing

Planning / setting up the ideal structure for a start-up, acquisition or association with American partners
« Treaty-Based Return: analysis of treaty-based position and filing of forms 1120-F / 8833 (U.S. tax return and mandatory disclosure)
U.S. sales taxes (registration, resale certificate, liability, exemptions, compliance, etc.)
Transfer pricing planning between Canada and foreign subsidiaries, tax optimization, preparation or review of required tax forms (forms T106 in Canada, and 5472 in the U.S.)
Assistance in obtaining an EIN (Employer Identification Number) and preparing the W8-BEN-E required by U.S. customers

U.S. Tax Returns for U.S. (Form 1120) or Foreign (Form 1120-F) Joint Stock Companies
U.S. Partnership Tax Returns (Form 1065/Schedule K-1)
U.S. state taxation: nexus analysis, state risk determination, registration, state tax filing, voluntary disclosure, etc.
State returns (income tax, franchise tax , gross receipts tax, margin tax or other, depending on the regime in force in the applicable state) and any other applicable jurisdiction
Preparation of any other applicable tax forms

Analysis of the tax obligations of individuals working in the United States
Analysis of tax obligations of U.S. citizens or permanent residents of the U.S. (green card holders), living in Canada or in any other country, including the disclosure of foreign banks accounts (FBAR / FINCEN 114)
Preparation of the various tax returns required on an annual basis (Forms 1040 or 1040-NR)
Preparation of any related forms, such as Form 5471, to disclose the ownership of non-U.S. shares (such as Canadian shares), based on certain criteria, by a U.S. citizen, Green Card holder or US resident
Canadian residents studying in the U.S. (tax consultation and preparation of Form 8843)
Assistance in obtaining an Individual Taxpayer Identification Number (ITIN) for U.S. tax compliance purposes
Voluntary disclosure for U.S. citizens or green card holders who have not filed their U.S. tax returns (under various tax programs/procedures)
Assistance with renunciation of U.S. citizenship or abandonment of green card status

Snowbirds: Consultation and preparation of form 8840 required by U.S. tax authorities for any individual staying in the U.S. for an extended period of time
Ownership, rental or sale of real estate in the U.S
Estate tax, evaluation, planning and preparation of form 706.
Gift tax, evaluation, planning and preparation of form 709
Assistance in obtaining an ITIN (Individual Taxpayer Identification Number) for US tax compliance purposes