Regulation 105 and Waivers
This posting was authored by Graham Purse, an Associate in the Regina office of Miller Thomson LLP. General Every person paying to a non-resident person a fee, commission, or other amount in respect of services rendered in Canada must withhold 15%...
2013 Corporate Tax Rates for Non-Residents Carrying on Business in Canada
This posting was authored by Crystal Taylor, a Partner in the Saskatoon office of Miller Thomson LLP Foreign companies that want to carry on business in Canada generally do so through a Canadian branch or a Canadian subsidiary. This BLOG...
No Consolidated Taxation of Corporate Groups in Canada
No Consolidated Taxation of Corporate Groups in CanadaThis posting was authored by Crystal Taylora Partner in the Saskatoon Office ofMiller Thomson LLP Canada does not have a formal system of corporate group taxation like the United States and other jurisdictions....
New Budget Rules for Non-Residents Carrying on Business in Canada
This posting was authored by Crystal Taylor, a Partner in the Saskatoon Office of Miller Thomson LLP On March 21, 2013, the Minister of Finance, Jim Flaherty, tabled the 2013 Federal Budget (the “Budget”) entitled Jobs, Growth and Long-Term Prosperity...
Important Considerations in Corporate Immigration to Leap the LMO Hurdle
This posting was authored by Haidah Amirzadeh and Kit McGuinness, Miller Thomson LLP. With a hot provincial economy, young work force, and comparatively low corporate and personal tax rates, Saskatchewan has become a very popular province for foreign investment. While foreign...
Withdrawal of General Preferential Tariff (GPT) Treatment for Certain Countries
This posting was authored by Katherine Xilinas, Miller Thomson LLP. In the early 1970s, the United Nations Conference on Trade and Development recommended that developed nations grant non-reciprocal duty reductions in respect of importations of goods originating in developing countries in...
Canadian Thin Capitalization Regime
This posting was authored by Lyne M. Gaulin and John M. Campbell Miller Thomson LLP Existing Canadian Thin Cap Regime The existing Canadian thin cap regime protects the Canadian tax base from excessive interest deductions by limiting the amount of...
Cross-Border Consequences of Secondment
Cross-Border Consequences of Secondment This posting was authored by Cheryl Teron and Stephen Rukavina Miller Thomson LLP. Secondment often involves one company (the “Lending Employer”) lending its employees to another related company in another country (the “Receiving Employer”) for the...
Carrying on Business in Canada
This posting was authored by Crystal Taylor, a Partner in the Saskatoon office of Miller Thomson LLP. As a general rule, a non-resident is prima facie liable to pay Canadian income tax on business income earned in Canada if the non-resident...
What you Need to Know to Incorporate a Canadian Subsidiary Corporation
General One option for a foreign entity seeking to do business in Canada is to create a Canadian Subsidiary Corporation. An advantage of a subsidiary over a branch structure is that a subsidiary allows the foreign entity to portray a...
