6th Taxation of Inbound Investment

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Brandon D. Wiener presents Taxable Canadian Property

September 12 & 13, 2012, Toronto | 6th Taxation of Inbound Investment

Topic Brief Non-residents of Canada are subject to Canadian capital gains tax or income tax on a disposition of taxable Canadian property (TCP), unless a treaty exemption is available. This session will examine issues involving taxable Canadian property. more	Bio Brandon Wiener is a partner of Thorsteinssons LLP. His practice focuses on personal, corporate and trust planning for high net worth individuals, professionals, executives, owner-managers and their businesses, both domestic and international more
Course Highlights Review the impact of the Fifth Protocol to the Canada-U.S. Income Tax Convention Examine the current issues surrounding taxable Canadian property Assess the elimination of withholding tax on cross-border interest payments Analyze the potential consequences of the new limitation on benefits provision Explore issues involving sales tax Review the planning and structuring of inbound investments tax-efficiently Understand payroll obligations Examine withholding tax requirements on nonresidents Assess the implications of changes to the permanent establishment rules Prepare for the mandatory arbitration of treaty disputes Examine recent cases relevant to inbound investment more	Event's Topics Canada-U.S. tax treaty: corporate tax planning opportunities Taxable Canadian property Thin capitalization & withholding tax Treatment of Hybrid Entities Limitation on benefits provision Permanent Establishment for Service Companies Payroll issues Withholding on services provided by nonresidents in Canada Mandatory Arbitration and Audit Controversy more
Workshop Effective Tax structuring of inbound investments This workshop will examine cross-border tax structuring, focusing on best practices in planning and structuring cross-border inbound investments into Canada, taking into consideration the latest development of inbound investment taxation policies, tax legislation and administrative practices. Structuring of the inbound investment: the choice of entity Financing Canadian investments: debt and equity financing Using hybrid entities and instruments to finance Canadian investments Planning for repatriating profits from Canada in a tax-efficient manner more	Participating Organizations Blake, Cassels & Graydon LLP Chapman and Cutler LLP Deloitte & Touche LLP Ernst & Young LLP Fasken Martineau DuMoulin LLP Gowling Lafleur Henderson LLP Miller Thomson LLP Norton Rose LLP Osler, Hoskin & Harcourt LLP Thorsteinssons LLP more
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