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International Tax Services

International tax issues can arise whenever a business, investment or individual has connections to more than one country.

We provide Canadian international tax advisory and compliance services for non-residents carrying on business or investing in Canada, as well as Canadian businesses and individuals with foreign operations, investments or assets.

Non-Residents Doing Business in Canada

Foreign businesses operating in Canada may have Canadian income tax, withholding tax and GST/HST obligations even without a Canadian corporation.


We assist with issues including:


  • Carrying on business in Canada

  • Permanent establishment exposure

  • Canadian corporate tax filings

  • Regulation 102 and Regulation 105 withholding

  • GST/HST registration

  • Treaty-based filing positions


Canadian Businesses Expanding Abroad

Canadian businesses with foreign subsidiaries, operations or investments can face complex Canadian tax and reporting requirements. We assist with:


  • Foreign affiliate planning

  • FAPI calculations

  • Foreign surplus calculations

  • T1134 reporting

  • Foreign tax credits

  • Repatriation of foreign profits

  • Cross-border corporate structures


Moving to or From Canada

Moving between countries can trigger significant Canadian tax consequences. We advise individuals on:


  • Canadian tax residency

  • Departure tax

  • Immigration to Canada

  • Foreign assets and investments

  • Principal residences and rental properties

  • Foreign reporting requirements


Non-Resident Real Estate

We assist non-residents with Canadian real estate tax matters, including:


  • Section 116 clearance certificates

  • Rental income and Section 216 returns

  • NR6 filings

  • Withholding tax

  • Dispositions of Canadian real estate


Foreign Assets and Investments

Canadian residents with foreign assets may have additional income inclusion and reporting obligations. We assist with matters involving:


  • Foreign investment income

  • Foreign corporations

  • Foreign trusts and entities

  • T1135 reporting

  • Foreign tax credits

  • Cross-border ownership structures


Cross-Border Tax Planning Before Transactions Occur

International tax consequences are often difficult to fix after a transaction has already taken place.


We work with clients before they expand internationally, move countries, purchase foreign investments or restructure their affairs so that Canadian tax consequences can be considered in advance.


Specialized Canadian International Tax Advice

International tax is a core focus of our practice.


Whether you are a foreign business entering Canada, a Canadian company expanding internationally or an individual with cross-border tax issues, we can help you understand the Canadian tax implications and navigate the associated compliance requirements.

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