International Tax

Learn how to prepare Form T1134 through a worked example involving a Canadian individual who owns a U.S. operating company, including ACB, loans, revenue and FAPI.

Learn how Canada's new Foreign Accrual Business Income (FABI) rules affect CCPCs with foreign affiliates, including FAPI, RTF elections, FABI surplus and the new section 93.4 rules.

Learn when a foreign affiliate’s active business income can become FAPI under Canada’s foreign affiliate rules, including services and related-party sales.

Learn how Canada’s FAPI rules apply to foreign affiliates, including controlled foreign affiliates, investment business income and the foreign accrual tax deduction.

Learn about Canada’s departure tax, including deemed dispositions, excluded assets, Forms T1161 and T1243, and tax obligations when leaving Canada.

Learn how Canadian tax residency is determined, including CRA residential ties, the 183 day deemed resident rule, and tax treaty tiebreaker rules.

Expanding into Canada? Compare Canadian branch vs subsidiary tax issues, including corporate tax, withholding tax, branch tax and audit exposure.

Learn how Regulation 102 and 105 withholding applies to non-resident employees and service providers working in Canada, including waivers.

Learn when a foreign company may be carrying on business in Canada, how permanent establishment rules apply and when tax filings may be required.

Non-resident earning Canadian rental income? Learn how Section 216 returns, NR6 forms and Part XIII withholding tax rules work in Canada.