Tag archives: tax considerations

Non-resident employees: withhold on worldwide income?

By Carl Deeprose (Toronto) 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