Investment in Shares of Foreign Affiliate or subsidiary

Learning Objectives

• To take an overview of Canadian tax implications of investing and owning shares of Foreign Corporations or subsidiaries
• To identify the effective strategies to minimize tax for inbound and outbound clients and the tax implications of cross-border transactions
• To recognize issues concerning international tax treaties and international tax avoidance (and evasion)
• To explore the tax compliance requirements such as Branch tax, T1134 – Foreign affiliate reporting, T106 – Reporting transactions with related non-residents

Course Description

The online tax CPE webinar offers a general overview of Canadian tax implications of investing and owning shares of Foreign Corporations or subsidiaries, especially those Canadian businesses that operate internationally or are considering expansion outside of Canada.

This webinar explores the effective strategies to minimize tax for inbound and outbound clients and the tax implications of cross-border transactions (e.g. foreign corporations doing business or investing in Canada; Canadians doing business or investing overseas; and transactions between members of multinational corporate groups). It will also cover issues concerning international tax treaties and international tax avoidance (and evasion).

This tax CPE webinar will also explore the tax compliance requirements such as Branch tax, T1134 – Foreign affiliate reporting, T106 – Reporting transactions with related non-residents.

Key topics included in this tax webinar:

• Introduction to Taxation of Foreign Affiliate – Basics, Surplus pools, and FAPI
• Introduction to Taxation of Foreign Affiliate
• Equity percentage, control, and look-through rules
• Active Business and Investment Business
• Foreign Accrual Property Income (FAPI)
• Excluded Property vs. Investment property
• Base Erosion Rules and Income Recharacterization
• Overview of Upstream Loans and Foreign Affiliate Dumping Rules
• Cross Border Financing and related tax implications
• Strategies to repatriate profits – Return of Capital, Loans, Dividend or Management Fee
• Inter-company transactions and Loans outstanding to related non-resident corporations

Who will benefit:

This CPE webinar is designed for Tax professionals who: would like a comprehensive overview of Canada’s international tax system; advise corporations on cross-border taxation issues; provide services to the cross-border client; work at a Canadian or foreign multinational company as a tax manager or director, or work in a government setting that deals with international tax for Canadian businesses.

Recommended for:

This CPE webinar is recommended for any Professional or Staff Member Involved in Preparation or Review of various type of Tax returns.

Overview

• International tax: Inbound vs Outbound

  5 mins
• Foreign Affiliate Tax Regime

  22 mins
• Controlled Foreign Affiliate

  47 mins
• Overview of FAPI Rules

  74 mins
• Deemed FAPI - Services Income 95(2)(b)

  112 mins
• Capital gain on shares of FA may be fully exempt from tax in Canada

  143 mins
• Doing business in Canada - Common Structures for tax purposes

  164 mins
• Deemed Interest Income - ITA 17(1)

  188 mins
• Repatriation strategies

  203 mins