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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Thursday, November 16, 2023

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00
CLE
CPE
ALL

This CLE/CPE course will provide tax counsel and advisers an in-depth analysis of Canadian tax considerations for U.S.-based taxpayers. The panel will discuss the Canadian tax system as applied to U.S.-based taxpayers, doing business in Canada considerations, acquisitions and financing Canadian operations, the Canada-U.S. Treaty, and other key items to consider for U.S.-based taxpayers.

Faculty

Alex Smith
Partner
Grant Thornton

Mr. Thornton has spent over 20 years providing services to multinational clients investing into and out of Canada. His experience includes dealing with cross-border acquisitions and divestitures, structured financing and cash repatriation strategies, as well as assisting foreign-based multinationals in the development of worldwide tax minimization plans. 

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Matias Milet
Partner
Osler, Hoskin & Harcourt LLP

Mr. Milet advises on Canadian tax issues associated with cross-border business ventures and transactions, investment funds and pension funds. His practice has included a broad range of transactions and advice to Canadian and international clients involving tax treaties, the taxation of trusts, corporations and partnerships and the taxation of investments in private equity, infrastructure and real estate by pension funds. Mr. Milet has taught international tax at the University of Toronto Faculty of Law and is currently a member of the Editorial Board of the Canadian Tax Journal.

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Description

Companies and private equity firms that own assets, carry on business, or have investments in Canada are subject to Canadian taxation unless a treaty exemption applies. Tax counsel and advisers must have a complete understanding of applicable tax rules to identify tax risks and carefully implement strategies to minimize tax liability.

For U.S.-based businesses with offices or assets in Canada, tax planning is key in order to avoid unintended tax liability. Canadiana tax filing obligations can arise where a U.S. resident carries on business in Canada or disposes of taxable Canadian property. With employees travelling in Canada, filing obligations can become costly and onerous.

Listen as our panel discusses the Canadian tax system as applied to U.S.-based taxpayers and offers tax planning strategies to obtain optimum tax benefits for U.S. individuals and businesses.

Outline

  1. Overview of Canadian tax regime for U.S.-based taxpayers
  2. Carrying on business considerations
  3. Canada-U.S. Treaty
  4. Tax issues for U.S.-based businesses
  5. Acquisitions, financing Canadian businesses
  6. Best practices and pitfalls of doing business in Canada

Benefits

The panel will review these and other key issues:

  • How do Canadian taxes apply to U.S.-based taxpayers?
  • What are the challenges for U.S.-based businesses with assets or offices in Canada?
  • What are the challenges and benefits of the Canada-U.S. Treaty?
  • What are the pitfalls to avoid and best practices for tax professionals?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Ascertain key components of the Canadian tax regime's impact on U.S.-based taxpayers
  • Identify key issues for U.S.-based taxpayers stemming from the MLI
  • Understand the components and mechanics of treaty-based structures to limit taxation
  • Ascertain methods to ensure the avoidance of capital gains for the disposition of Canadian-based assets by U.S. taxpayers

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other preparers/accountants. Specific knowledge and understanding of foreign information reporting requirements, including FATCA and FinCEN Form 114; familiarity with foreign income sourcing rules and tax treaty provisions.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).