Tag archives: Canada Revenue Agency

Non-resident employees: withhold on worldwide income?

By nrfdigitalteam on May 9, 2019 Posted in Employment and labour, Tax

ITA regulation 102 requires employers to withhold tax on remuneration paid to non-resident employees who are employed in Canada. This requirement can be avoided by seeking a treaty-based waiver (regulation 102 waiver) or certification as a qualifying non-resident employer. However, often there is not sufficient time to do this before the employment is to begin, or there … Continue reading

Private equity and Canadian partnerships: tax considerations

By Troy Ungerman (Toronto) on June 7, 2018 Posted in Finance, Real estate

Canada continues to be an attractive market for private equity (“PE“) investors with recent transactions highlighting significant investments into Canadian real estate and energy infrastructure assets. Partnerships (particularly, limited partnerships) continue to be a popular PE vehicle, providing a means of pooling and aggregating investment funds and allowing for income or losses to be “flowed-through” … Continue reading

Incoming legislation implements common reporting standards

By Troy Ungerman (Toronto) on May 11, 2017 Posted in M&A, Tax

On July 1, amendments to the Income Tax Act (Canada) implementing international common reporting standards (CRS) will come into force. The CRS regime is intended to facilitate the exchange of taxpayer information between governments. Financial institutions will be required to report financial information about individuals and entities not resident in Canada[1] to the Canada Revenue … Continue reading

Tax considerations for earn-outs and reverse earn-outs

By Troy Ungerman (Toronto) on September 15, 2016 Posted in M&A, Tax

As we have previously noted, earn-outs are becoming an increasingly common part of M&A deals, and there are a number of key commercial questions to consider when negotiating them. But there are also tax consequences that must be considered when structuring earn-outs. Earn-outs link a portion of total purchase price to the performance of the … Continue reading

Getting the best (asset) deal: tax efficient purchase price allocations

By Troy Ungerman (Toronto) on April 26, 2016 Posted in Corporate finance, Tax

The number one consideration for anyone buying or selling a business is price. But getting the best price is not just about the total cash value. How the purchase price is allocated across the various assets included in the deal has significant implications for the future tax liabilities of both purchasers and sellers. This article … Continue reading