Investing in Canada

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Why Would Anyone Want an Unlimited Liability Company?

This posting was authored by Stephen Rukavina, an Associate in the Vancouver Office of Miller Thomson LLP An unlimited liability company (“ULC”) is a common entity US businesses use as a Canadian subsidiary or to hold Canadian assets.  This can seem...

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Part XIII Tax: Withholding Tax on Canadian-Source Income

Introduction When a Canadian resident makes a payment to a non-resident, the Canadian payor is required to withhold 25% in certain circumstances. Generally, the requirement arises where the payment is of a passive nature – this includes interest, dividends, rents,...

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GST/HST & Asset Sales: The Section 167 Election

This posting was authored by Stephen Rukavina, an Associate in the Vancouver Office of Miller Thomson LLP Introduction The goods and services tax (“GST”) is a value-added tax charged on most supplies made in Canada of goods, services, real property and...

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An Overview of Transfer Pricing In Canada

This posting was authored by Stephen Rukavina, an Associate in the Vancouver Office of Miller Thomson LLP Introduction In Canada v. GlaxoSmithKline Inc. (“GlaxoSmithKline”), Justice Rothstein of the Supreme Court of Canada succinctly summarized transfer pricing and the tax concerns...

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Meaning of Carrying On Business in Canada

This posting was authored by Crystal Taylora Partner in the Saskatoon Office and Graham Pursean associate in the Regina Office ofMiller Thomson LLP As a non-resident engaging in activities in Canada, it is important to understand whether your activities will...

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Canada’s anti-spam legislation (CASL) will affect non-residents who carry on business in Canada

In December 2013, the Canadian federal government announced[1] firm dates for Canada’s anti-spam legislation (commonly referred to as CASL) to come into force, some three years after Bill C-28 (the operative bill) received Royal Assent in December 2010.[2] Implementation Dates...

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A Non-Resident Disposing of Taxable Canadian Property

This posting was authored by  Cheryl Teron, a Partner in the Vancouver Office of Miller Thomson LLP and Stephen Rukavina, an Associate in the Vancouver Office of Miller Thomson LLP A non-resident of Canada may have to pay Canadian income tax on taxable capital...

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The Restrictive Covenant Taxation Scheme: Killing a Fly with a Sledgehammer

This posting was authored by Stephen Rukavina an Associate in the Vancouver Office of Miller Thomson LLP The Federal Court of Appeal’s decisions in Canada v. Fortino and Manrell v. Canada held that payments for a non-competition agreement were not...

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Think Twice Before Using an LLC in Canada

This posting was authored by Cheryl Teron a Partner in the Vancouver Office of Miller Thomson LLP and Stephen Rukavina an Associate in the Vancouver Office of Miller Thomson LLP Introduction A limited liability company (“LLC”) is a common type...

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Goods and Services Tax: An Overview for Non-Residents

This posting was authored by Cheryl Teron a Partner in the Vancouver Office of Miller Thomson LLP and Stephen Rukavina an Associate in the Vancouver Office of Miller Thomson LLP The Basics The goods and services tax (GST) is a value-added...

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Displaying 1-10 of 22

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