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Investment in Shares of Foreign Affiliate or subsidiary

  • Accountant
  • CPA (CA)

Published: May, 2021

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  • Course Description
  • Course Qualification
  • Presenter
  • FAQ

Course Description

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

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.

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

Recommended For

  • Any Professional or Staff Member Involved in Tax Planning for Clients.

Who Should Attend?

  • Accountant
  • Accounting Firm
  • Accounting Managers
  • Bookkeepers & Accountants & Tax Preparers
  • California Registered Tax Professional
  • Chief Accounting Officer
  • Cloud Accountants
  • CPA (Industry)
  • CPA - Mid Size Firm
  • CPA - Small Firm
  • CPA in Business
  • Entrepreneurial Accountant
  • Entrepreneurial CPA
  • Maryland Tax Preparers
  • Oregon Tax Preparers
  • Senior Accountant
  • Staff of Accounting Firm
  • Tax Accountant (Industry)
  • Tax Attorney
  • Tax Director (Industry)
  • Tax Firm
  • Tax Managers
  • Tax Practitioners
  • Tax Preparer
  • Tax Professionals
  • Tax Pros
  • Young CPA

Course Qualification

Webinar Qualifies For

  • 4.5 CPD Credit of Taxes for Chartered Professional Accountant (CPA Canada)
  • 4.5 General Credit of Taxes for Accountant/Bookkeeper/Tax Professionals

Additional details

  • Course Level :
    Basic
  • Credits :
    4.5
  • Instructional Method :
    QAS Self Study
  • Pre-requisites :
    None
  • Advance Preparation :
    None

Presenter

About Presenter

Big4 CPA

Founder, AK Consulting Inc.

We are a team of Big4 CPA, CA and other professionals. We offer wide range of professional development courses for CPA members relating to Canadian Taxation, International tax, Accounting, Ethics, Business, Workplace Teams & Culture, High Performance, Soft skills, and Personal Development.

We also work with third party content creators to offer unique CPD for our CPA members, such as on latest technology, cyber security, digital marketing. and various other interesting topics.


Faq

FAQs content

  • To receive Continuing Education credit for the event, you must register for the webcast prior to the start of each program.
  • Continuing Education Credit Certificate is available to all eligible participants within 24 hours of each webinar.
  • You must attend complete live webinar and respond to all polling questions asked during the webinar. Credits would be issued on 50 minute credit hour basis.
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  • This event may be a recorded rebroadcast of a live event done in past and the instructor will be available to answer your questions during/after the webinar.
  • If you still face the polling problem please don’t panic and provide your response in the chat and we shall consider the same for processing for credits. You can download Zoom by clicking on the mentioned link : https://zoom.us/download
  • Our courses meet the global Continuing Professional Development (CPD-IES7) Standard for Chartered Accountants with International Education Standard 7 (IES 7) set by The International Federation of Accountants (IFAC), the International Accounting Education Standards Board (IAESB) and the Association of Chartered Certified Accountants (ACCA). Based on our accreditation by existing IFAC members and affiliates, we believe learners can count their professionally relevant, verifiable learning activities on myCPE, including taking on demand courses and attending live webinars, toward fulfillment of their verifiable CPD-IES7 requirements. However, if there is any question, we recommend that the individual learner confirm with his/her professional licensing organization before taking myCPE courses for CPD-IES7 credit.
  • You can manage your continuing education certificates and credits through your certificate dashboard which is available when you are logged in to your account (LOGIN)
  • As an accredited provider of Continuing Professional Education in the United States, myCPE online learning platform, courses, and webinars meet the requirements set forth by the Institute of Management Accountants (IMA), an IFAC Member Organization, as well as the National State Boards of Accountancy (NASBA) and the Institute of Internal Auditors (IIA), both IFAC Affiliates. As well as it has been approved by NASBA, Internal Revenue Service (IRS), Certified Financial Planner Board (CFP Board), California Tax Education Council (CTEC), Society of Human Resource Professional (SHRM), Human Resource Certification Institute (HRCI) and many more.Therefore, we believe learners can count their professionally relevant, verifiable learning activities on myCPE, including taking on demand courses and attending live webinars, toward fulfillment of their verifiable continuing education requirement as CPD-IES7 requirements. However, if there is any question, we recommend that the individual learner confirm with his/her professional licensing organization before taking myCPE courses for CPD-IES7 credit.
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Ratings and Review

5

1 Ratings

Excellent

1

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0

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KH

Kenneth Huang, CPA (CA), CMA, CPA-ON

Jan 1st, 2022

good

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