🌐 International Taxation

We offer technical expertise applied to complex international tax issues, grounded in a thorough knowledge of Canadian legislation and its interactions with foreign tax regimes.

Our approach is to provide rigorous, cross-border-specific analysis — ensuring compliance, effective tax risk management, and optimal tax treatment in an international context.

• Analysis of rules applicable to foreign affiliates, including the concepts of active business income and passive income
• Surplus computations (exempt, taxable, and hybrid)
• Reorganizations involving foreign affiliates
• Foreign Accrual Property Income (FAPI)
• International financing structuring (debt and equity)
• Tax analysis of partnerships in a cross-border context
• Non-resident taxation in Canada (inbound)
• Analysis and qualification of permanent establishments
• Interpretation and application of tax treaties
• Allocation of taxing rights between jurisdictions
• Withholding tax optimization