Most business transactions have a tax component. We have experience in identifying tax issues, working closely with clients' accounting advisors and preparing legal documentation necessary to support desired tax outcomes.
- Tax litigation - Canada Revenue Agency appeals, Tax Court of Canada, Federal Court of Appeal
- Tax minimization - strategies such as estate freezes (limiting growth in value of one person's shares - typically parent - so that future growth can accrue to children, children's trust, etc. )
- Eligibility for venture capital tax credits (30% )
- Eligibility opinions required to hold shares of private companies in RRSP/RRIF's
- GST/PST/Hotel Tax, etc.
- Ensuring requirements for $750,000 lifetime capital gains exemption are met
- Flow Through Shares - renunciation of oil and gas/mining/exploration expenses
- Scientific research and development tax credits
- Advise on directors/executors liability
- Apply for Clearance Certificates (e.g. estates)
- Apply for Advance rulings from the Canada Revenue Agency as proposed transactions
- Ceasing to become resident of Canada
- Becoming resident of Canada
Practice Tip: The key thing with tax is to identify issues. A taxpayer is still entitled to arrange his affairs to pay as little tax as possible. Paying the least amount of tax can often be accomplished through careful planning and proper documentation. Many tax plans fail or are challenged due to inadequate documentation/records. In addition, cross-border situations need to be addressed; for example a US citizen resident in Canada may still be liable for US tax even though gains in Canada may be exempt.
