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Corporate Tax Rates for Non-Residents Carrying on Business in Canada
Foreign companies that want to carry on business in Canada generally do so through a Canadian branch or a Canadian subsidiary. This post outlines the general tax rates for non-residents carrying on business in Canada using one of those structures. […]
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Canadian Thin Capitalization Regime
This posting was authored by Lyne M. Gaulin and John M. Campbell Miller Thomson LLP Existing Canadian Thin Cap Regime The existing Canadian thin cap regime protects the Canadian tax base from excessive interest deductions by limiting the amount of […]
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Why Would Anyone Want an Unlimited Liability Company?
This posting was authored by Stephen Rukavina, an Associate in the Vancouver Office of Miller Thomson LLP An unlimited liability company (“ULC”) is a common entity US businesses use as a Canadian subsidiary or to hold Canadian assets. This can seem […]
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Part XIII Tax: Withholding Tax on Canadian-Source Income
Introduction When a Canadian resident makes a payment to a non-resident, the Canadian payor is required to withhold 25% in certain circumstances. Generally, the requirement arises where the payment is of a passive nature – this includes interest, dividends, rents, […]
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GST/HST & Asset Sales: The Section 167 Election
This posting was authored by Stephen Rukavina, an Associate in the Vancouver Office of Miller Thomson LLP Introduction The goods and services tax (“GST”) is a value-added tax charged on most supplies made in Canada of goods, services, real property and […]
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An Overview of Transfer Pricing In Canada
This posting was authored by Stephen Rukavina, an Associate in the Vancouver Office of Miller Thomson LLP Introduction In Canada v. GlaxoSmithKline Inc. (“GlaxoSmithKline”), Justice Rothstein of the Supreme Court of Canada succinctly summarized transfer pricing and the tax concerns […]
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A Non-Resident Disposing of Taxable Canadian Property
This posting was authored by Cheryl Teron, a Partner in the Vancouver Office of Miller Thomson LLP and Stephen Rukavina, an Associate in the Vancouver Office of Miller Thomson LLP A non-resident of Canada may have to pay Canadian income tax on taxable capital […]
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The Restrictive Covenant Taxation Scheme: Killing a Fly with a Sledgehammer
This posting was authored by Stephen Rukavina an Associate in the Vancouver Office of Miller Thomson LLP The Federal Court of Appeal’s decisions in Canada v. Fortino and Manrell v. Canada held that payments for a non-competition agreement were not […]
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Goods and Services Tax: An Overview for Non-Residents
This posting was authored by Cheryl Teron a Partner in the Vancouver Office of Miller Thomson LLP and Stephen Rukavina an Associate in the Vancouver Office of Miller Thomson LLP The Basics The goods and services tax (GST) is a value-added […]
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Think Twice Before Using an LLC in Canada
This posting was authored by Cheryl Teron a Partner in the Vancouver Office of Miller Thomson LLP and Stephen Rukavina an Associate in the Vancouver Office of Miller Thomson LLP Introduction A limited liability company (“LLC”) is a common type […]
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Regulation 105 and Waivers
This posting was authored by Graham Purse, an Associate in the Regina office of Miller Thomson LLP. General Every person paying to a non-resident person a fee, commission, or other amount in respect of services rendered in Canada must withhold 15% […]
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Meaning of Carrying On Business in Canada
This posting was authored by Crystal Taylora Partner in the Saskatoon Office and Graham Pursean associate in the Regina Office ofMiller Thomson LLP As a non-resident engaging in activities in Canada, it is important to understand whether your activities will […]
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No Consolidated Taxation of Corporate Groups in Canada
No Consolidated Taxation of Corporate Groups in CanadaThis posting was authored by Crystal Taylora Partner in the Saskatoon Office ofMiller Thomson LLP Canada does not have a formal system of corporate group taxation like the United States and other jurisdictions. […]
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Cross-Border Consequences of Secondment
Cross-Border Consequences of Secondment This posting was authored by Cheryl Teron and Stephen Rukavina Miller Thomson LLP. Secondment often involves one company (the “Lending Employer”) lending its employees to another related company in another country (the “Receiving Employer”) for the […]
