Publications

In the intricate world of international taxation, Canadian taxpayers with global interests often find themselves at the crossroads of domestic tax compliance and international investment opportunities. A critical aspect of this landscape is understanding the Foreign Accrual Property Income (FAPI) tax rule, a cornerstone of Canadian tax regulation designed to curb tax avoidance through Controlled...

In the realm of Canadian tax law, non-resident trusts (NRTs) present a unique blend of challenges and opportunities, especially after the substantial revisions to Section 94 in 2013. The primary objective of these changes was to curb the avoidance or deferral of Canadian income tax via NRTs. Understanding these rules is crucial for tax planning...