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Calgary Corporate Law Blog

Handling transfer price challenges and disputes

Businesses that operate globally may well have a transfer pricing policy in place. These policies serve as an accounting strategy to determine transactional costs across divisions. A transfer pricing policy can also be an effective tax avoidance practice by allocating profits across international parts of the organization.

However, numerous challenges can arise when it comes to these intercompany pricing policies due to their complexity and the potential for illegal or abusive conduct.

4 mistakes to avoid after receiving a letter of intent

Selling a business is complicated and stressful. Business owners can have a lot at stake, and there are many moving parts that affect valuations, price and conditions of the transaction.

At the first sign that a sale could happen, which could be receiving a letter of intent, it can be easy to get anxious and want to push forward as quickly as possible. However, moving too fast is one common mistake people can make at this stage, as are the missteps we examine below.

What you should know about Shareholder Agreements

Shareholder agreements can be powerful tools to safeguard your interests as an owner of a company. In part, it outlines the rights and privileges of various shareholder positions, and the duties and responsibilities of key members of the organization.

If you are the only owner of your business, a shareholder agreement may not be necessary. But once you have multiple stakeholders, it’s crucial that you have a set of rules for how to approach and resolve potential disagreements or conflicts if they arise.

What’s In A (Corporate) Name?

You may have already figured out an idea for a business. You may have already figured out how you will operate your business, secure financing and how it will grow. But what can be difficult for many is picking the name of your business when you incorporate.

There are certain requirements and restrictions that go into naming a corporation. It’s important to make sure that when you do settle on a name, it suits your business and is legally acceptable.

Social Media And Corporations: What You Need To Know

As companies look for ways to expand their reach and attract new customers, the importance of updating social media is becoming more apparent. It’s a great way to cast a wider net to reach more consumers, and to foster greater engagement with their brand.

However, there are some issues that companies should stay clear of when beefing up their online presence. The Government of Canada has posted some helpful tips that business owners and corporations should consider when posting sharable content.

Estate Freezes Reduce Tax Liability And Simplify Estate Planning

Sole owners of corporations who want to minimize their taxes or create make family succession plans for a thriving business should consider implementing an ‘estate freeze’. Owners can use estate freezes to restructure their company’s ownership by limiting the value of the owner’s assets and transferring future growth to the owner’s family. This allows owners to reduce the amount of taxes that they have to pay.

Objectives Of Estate Freezes

Transfer Pricing - Facing CRA Audits As A Multinational Business

In our last post, we looked at the basic concept of transfer pricing. Any business that buys and sells to a foreign entity under its own corporate group may, at some point, be called upon by the CRA to defend the transfer price for those international transactions.

If that price doesn't match up with an amount that unrelated companies would normally agree to - the arm's length price - a transfer price dispute could ignite. Is your business at risk? Is it possible to successfully face the CRA and ward off increased taxation and penalties?

Transfer Pricing 101 - What Any Multinational Business Needs To Know

Google, Starbucks, Amazon - some of the biggest businesses in the Western world have been embroiled at some point in high-stakes tax disputes over transfer pricing. Yet, international tax woes are not confined to blue-chip corporations. Any business with corporate affiliates on foreign shores could become the target of a tax audit by the CRA.

What is transfer pricing? What do businesses risk? Why consult with a transfer pricing lawyer? Our post provides the basics - simplified and in plain English.

The basics of the law, the guidelines, the circulars, the TPMs, and how they relate to Canadian transfer pricing

An understanding of the nature and significance Provisions of Canadian law, the OECD guidelines (Guidelines), and the administrative circulars and memoranda of the Canada Revenue Agency (CRA) as set forth in Circulars and Transfer Pricing Memorandums (TPM) is critical to understanding transfer pricing. All are all in a process of continual evolution. This memorandum is an explanation of the basics of each, and how they interact with each other.

Should I incorporate my business provincially, or federally?

When a Canadian small business is ready to incorporate, it has two options: Provincial or federal incorporation. The way in which a business incorporates can have long-lasting implications for its success. It is important for business owners to choose the method of incorporation that is the best fit for their company.

Provincial and federal incorporation have similarities and differences that business owners should take into careful consideration. In this post, we'll go over both types of incorporation--and which one could be right for your business. 

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