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...
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...
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...
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...
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...
Shaun MacIsaac commented on current post- BEPS issues including the new landmark Chevron case ... Shaun T. MacIsaac, Q.C. appeared with a panel of international experts at the Sofitel Hotel, London, UK on November 22, 2017, and provided comments that related to the...
You've built a successful business in Alberta, and the time comes that you consider selling it. Likely, your primary concerns are to find the right buyer and attain the best purchase price. However, you might also have serious concerns about maintaining the brand...
In the coming years, pundits have predicted that a trillion dollars of assets are to be transferred from current owners to the new generation in Canada over the next decade. Orderly planning for the tax, asset protection and wealth building opportunities have to be...
Acquisition International have conferred the award to for "Best for Transfer Pricing Disputes - Canada" for 2015. The firm is thrilled to be recognized internationally based on the criteria of peer review in this highly specialized...
Earlier this year, the Alberta government proposed a six-fold increase in most major Land Titles document registration costs. The stated purpose was one of several measures to cover an expected shortfall in government revenues. I think that the increased costs would...
PMR Law have been named the winner of the Business Law Firm of the Year 2017 Canada by CV Magazine and the Global 100 Excellence Award as Firm of the Year (Litigation Counsel) Canada. These awards are much appreciated by the firm. In everything we do, we strive to provide the best service for our clients.
