Cross-Border Tax Intelligence & Technical Analysis.
In-depth commentary, treaty interpretations, and strategic frameworks for global businesses, private wealth, and professional practice partners.
International tax law evolves constantly across jurisdictions. Our insights provide senior decision-makers and professional advisers with clear, actionable analysis on complex statutory changes, treaty developments, cross-border structuring, and global mobility risks.
- FEATURED INSIGHT00
Navigating OECD Pillar Two: What Mid-Market Multinational Groups Need to Know About the 15% Global Minimum Tax.
An executive breakdown of GloBE rules, domestic top-up taxes, and how foreign subsidiaries impact effective tax rates for expanding Canadian enterprises.
Louis Philippe Trottier5 Min Read - Corporate Expansion & M&A01
Branch vs. Subsidiary in Canada: Evaluating Permanent Establishment Risks and Regulation 105 Withholdings for Foreign Entrants.
How foreign businesses entering Canada should weigh a branch against a subsidiary, assess when Canadian activity becomes taxable, and manage the withholding that applies to fees for services performed in Canada.
Louis Philippe Trottier5 Min Read - Corporate Expansion & M&A02
Cross-Border M&A Tax Due Diligence: Key Exposure Areas in Target Corporations with Foreign Affiliates.
Where tax exposure typically sits when a Canadian target owns foreign subsidiaries, and how diligence findings translate into price, contractual protection and post-closing planning.
Louis Philippe Trottier4 Min Read - Global Mobility & Departure03
Severing Canadian Tax Residency: Navigating Departure Tax, Valuations, and Treaty Tie-Breakers.
Leaving Canada can trigger tax even when nothing is sold. This brief explains when residence ends, how the departure tax is measured and supported, and how treaty tie-breakers resolve competing residence claims.
Louis Philippe Trottier4 Min Read - Global Mobility & Departure04
The U.S.–Canada Snowbird & Executive Tax Guide: Days-Count Rules, Substantial Presence, and Form 8840.
How U.S. day-count rules apply to Canadians who winter in the United States or work on both sides of the border, and the filings that help keep a Canadian's U.S. tax position clear.
Louis Philippe Trottier5 Min Read - International Compliance & FAPI05
Understanding Foreign Affiliate Property Income (FAPI): A Structural Overview for Canadian Privately Held Corporations.
A structural overview of how Canada taxes passive income earned through foreign corporations, including the rules affecting Canadian-controlled private corporations and the surplus accounts that govern repatriation.
Louis Philippe Trottier4 Min Read - International Compliance & FAPI06
T1134 & T1135 Reporting Pitfalls: How Recent CRA Audit Trends Target Foreign Property Disclosures.
Why foreign property and foreign affiliate returns draw CRA attention, where filers commonly go wrong, and how to correct the record under the revised Voluntary Disclosures Program.
Louis Philippe Trottier4 Min Read - Private Wealth & Foreign Trusts07
Canadian Beneficiaries of Foreign Trusts: Taxation Rules, Contribution Liabilities, and Historical Regularization.
How Canada taxes foreign trusts with Canadian beneficiaries, when contributions can bring a foreign trust into the Canadian tax net, and how families can bring past reporting into a supportable position.
Louis Philippe Trottier5 Min Read