U.S. Tax and Cross-Border Tax Services

Investments or doing business in the United States or with U.S. businesses or individuals can take various forms. Equally, U.S. and non-U.S. investors (whether individuals or businesses) expanding into Canada or doing business with Canadians have various options on how they can structure their business operations. Each of those choices may have significant Canadian and/or U.S. tax implications. More importantly, in addition to cross-border and international tax issues, purely domestic Canadian and/or U.S. tax issues constantly arise for both businesses and individuals engaging in cross-border transactions. TaxChambers LLP uses an integrated approach in rendering cross-border services and provides comprehensive solutions to its clients from both Canadian and U.S. tax standpoint. TaxChambers LLP assists Canadian- and U.S.-based businesses and individuals in the following areas:

  • Choosing the tax-efficient form of doing business in the United States or in Canada (corporation, a flow-through entity, direct ownership, use of holding companies, joint ventures).
  • Financing of U.S. or Canadian operations to meet your business objectives while effectively managing your U.S., Canadian and global tax exposure and maximizing available tax benefits (tax structuring and implementation, including drafting relevant agreements and corporate resolutions).
  • Tax structuring of acquisitions and dispositions of U.S. and Canadian businesses, restructuring of Canadian and U.S. operations.
  • Tax due diligence.
  • * Review of existing transfer pricing policies and practices and developing transfer pricing strategies to meet your business objectives, including preparing planning and contemporaneous transfer pricing documentation, IRS audit defense, competent authority and Advance Pricing Agreement (APA) assistance. TaxChambers LLP also drafts intercompany agreements and assist in the implementation of developed transfer pricing strategies and policies.
  • FIRPTA (“Foreign Investment in Real Property Tax Act”) planning and structuring, including advice on related FIRPTA withholding and reporting requirements with respect to investments in and transactions involving U.S. real property.
  • Tax-efficient earnings repatriation planning.
  • Assistance with U.S. state and local income / franchise taxes and sales and use taxes.
  • Assistance to businesses entering the U.S. market via internet selling strategies and via use of intermediaries.
  • Assistance in obtaining the certifications of U.S. tax residency (IRS Form 6166).
  • PFIC (“Passive Foreign Investment Company”) planning and consulting.
  • Foreign Tax Credit (FTC) consulting.
  • Subpart F planning and consulting.
  • Tax treaty planning, including determination of eligibility for treaty benefits under the Limitation on Benefits (LOB) article of applicable U.S. income tax treaties.
  • Permanent establishment (PE) exposure analysis, including U.S. federal income tax and state and local tax considerations.
  • Estate and gift tax planning for high net worth individuals, including legal support and implementation.
  • Tax controversy, including assistance during the IRS audit and Appeals process.
  • U.S. tax withholding and information reporting advice.
  • * U.S. tax compliance, both for individual and businesses, including assisting corporations (including preparing and filing consolidated returns), U.S. tax compliance for U.S. corporations and partnerships. Providing assistance on an ongoing basis with filing extensions, estimated tax payments, including both U.S. federal and state and local tax compliance. U.S. tax compliance related calculations (U.S. tax basis, earnings and profits (E&P), IRC Section 382 ownership changes, and other areas).

*TaxChambers LLP provides these services with assistance of and in coordination with its trusted affiliated service providers.