We work with a wide range of clients including private businesses, owner-managers, multi-jurisdictional families and businesses, multi-national corporations and high net worth individuals to help them with tax efficient strategies. Our services include estate planning, corporate restructuring, international and Canada-US cross border planning and transfer pricing. Through Cadesky US Tax, we assist with US tax filings.
With our many years of experience, our professional team aims to deliver excellence in tax planning services. In addition to working in tandem with the client’s existing professional team, we have a wide network of professionals in Canada, the US and internationally which allow us to provide seamless services. We work in collaboration with the International Tax Specialist Group (ITSG). This international network enables us to access experienced Tax Professionals in over 50 countries around the Globe.
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Jul 12, 2019
The use of creative international structures by multinational corporations to transfer a significant portion of their global profits to low tax jurisdictions led the Organisation of Economic Co-operation and Development (“OECD”) to undertake the Base Erosion and Profit Shifting (“BEPS”) study. The study concluded with 15 proposed initiatives, one of which is to address potentially abusive use of tax treaties between countries to shift profits.
Jun 27, 2019
The Income tax act contains a number of anti-avoidance provisions. Subsection 55(2) apples to convert some intercorporate actual or deemed dividends into capital gains or proceeds of disposition, respectively..
This provision was created when capital gains tax rates were higher than dividends. The intent of the section is to allow companies to move their tax paid retained earnings (“Safe Income”) out of, say, an operating company to a holding company, tax free since intercorporate dividends of this nature are often tax free. There is no further tax paid until the amounts are paid out as dividends to a shareholder who is a “natural person” where the amounts are taxed as eligible or “ineligible” dividends.
Feb 26, 2019
A Canadian corporation’s first fiscal year can end up to 53 weeks after the date of incorporation. Once the fiscal period has been chosen, it cannot be changed, unless by operation of law, without the permission of the Canada Revenue Agency (“CRA”).
