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NAFTA Domestic Tax as Trade Subsidy

This paper argues that North American Free Trade Agreement (NAFTA) renegotiation and amendment should be used to define and restrict domestic tax provisions improperly used as indirect trade subsidies or tariffs. In doing so the Canadian foreign affiliate rules and the proposed US border adjustment tax are examined.

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US Real Estate Tax Issues

US Tax Issues for Canadians

This paper provides an overview of relevant tax considerations when a Canadian resident is purchasing US real estate and discusses different ways to structure a purchase to minimize tax exposure.

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Using a Family Trust in Business

Family Trusts for Business

The discretionary family trust is a tool used by some business owners to reduce tax liability and increase flexibility in the family economic unit by facilitating tax-favourable distribution of funds, business succession and estate planning. Using a discretionary family trust to hold shares in a private company can have significant tax and planning benefits. This paper seeks to provide an overview of the beneficial uses of a trust by the owner of a privately held corporation in Canada.

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Business Sale Tax Considerations

Business Puchase & Sale Tax Considerations in Canada

The purchase and sale of a private incorporated company in Canada raises a variety of important tax considerations. This paper provides an overview and analysis of such considerations and argues that the clear public policy objective of promoting small business in Canada using provisions of the Income Tax Act has been undermined by an unnecessarily complex regime. While many of the tax issues discussed also apply to the purchase and sale of public companies, the focus of this paper is on the purchase and sale of privately held corporations.

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