Our Core Capabilities

Strategic structuring and tax architecture for enterprises scaling globally, entering Canadian markets, or executing cross-border M&A transactions.

• 01.1Canadian Branch vs. Subsidiary & Transfer Pricing
• 01.2Cross-Border M&A, Tax Due Diligence & Valuation
• 01.3Buy/Sell-Side Support & Post-Transaction Modeling

Comprehensive tax navigation and cross-border planning for moving executives, global entrepreneurs, expats, and departing HNWIs.

• 02.1Departure Tax, Emigration & Deemed Dispositions
• 02.2Canadian & Treaty Residency Reviews (Tie-Breakers)
• 02.3Valuation of Global Assets & Tax Cost-Basis Setup

Embedded, on-demand global tax leadership for corporate CFOs and confidential white-label advisory for CPA and law practice partners.

• 03.1Outsourced Head of Global Tax Function (Retainers)
• 03.2White-Label Opinions & Technical Co-Counsel for Firms
• 03.3Multi-Jurisdictional Family Office Tax Oversight

High-net-worth estate preservation, foreign trust architecture, and intergenerational wealth structures across multi-country jurisdictions.

• 04.1Creation & Review of Foreign Trusts & Canadian Status
• 04.2Cross-Border Inheritance, Real Estate & Foreign Probate
• 04.3Intergenerational Wealth Transfers & Holding Structures

Rigorous compliance execution, audit defense, and structural regularization for foreign entities, foreign affiliates, and global assets.

• 05.1T1134 & T1135 Foreign Property Filings
• 05.2Foreign Affiliate & FAPI Analysis (Surplus & ACB)
• 05.3CRA Audits, Objections & Voluntary Disclosures

High-level technical analysis, formal written tax opinions, and policy guidance for complex multinational corporate and fund structures.

• 06.1Formal Legal & Technical Tax Opinions
• 06.2Tax Treaty Analysis & Permanent Establishment Risk
• 06.3OECD Pillar Two (GloBE Rules) & Profit Repatriation