Cross-Border and International Tax
Doing business across borders can raise complex international tax issues. Our clients rely on our expertise and experience for advice on a wide variety of international and cross-border transactions to allow them to pursue their commercial objectives while managing tax risk as efficiently and pragmatically as possible across multiple jurisdictions.
Our firm’s tax lawyers have expertise in a variety of jurisdictions and have experience working with local tax counsel and advisors all over the world. Fasken Martineau offers this expertise in a collaborative, time-sensitive, and client-friendly manner to ensure you receive the best outcome in any international transaction.
We regularly act for international business groups, financial institutions, funds (both private equity funds and hedge funds), family offices and individuals.
We provide advice on:
- Tax-efficient cross-border tax planning and structuring across the whole range of direct and indirect taxes
- Structuring inbound investment into Canada and South Africa including incorporation, business acquisitions or reorganizations and repatriation/exit strategies
- Advice on outbound investment out of Canada and South Africa including foreign affiliate structuring and reorganizations
- Double taxation treaty interpretation
- Transfer pricing including advance pricing arrangements, contemporaneous documentation, and transfer pricing disputes
- Implementation of Foreign Account Tax Compliance Act (FATCA) and the Organisation for Economic Co-operation and Development (OECD)’s Common Reporting and Due Diligence Standard reporting requirements
- Non-resident withholding tax planning and compliance
- Foreign property reporting obligations for non-resident businesses, individuals, and trusts and non-resident trust and deemed Canadian resident trust planning and reporting