Industries
Practice Areas
Offices

Corporate Taxation & Structuring in Canada and Canadian Scientific Research & Experimental Development Program Overview (SR&ED)

A Canadian Perspective on Canada-US Cross Border Tax Issues
March 15, 2011


Huntsville and Birmingham, AL, United States of America

Event participants:

Claude E. Jodoin

I.    Corporate Taxation in Canada

  • Applicable Income Tax Rates
  • Applicable Sales Tax Rates
  • Withholding Tax
  • Recent changes and opportunities
    • Changes to Domestic Rules: Disposition of TCP

II.     Choice of Entity

III.    Review of SR&ED

  • Review of SR&ED Incentives:
    • Federal Tax Incentives
    • Québec Tax Incentives
    • Ontario Tax Incentives
    • Alberta Tax Incentives
    • British Columbia Tax Incentives
  • General and Eligibility Requirements

IV.     Structuring Ideas and Issues

  • Structures for SR&ED:
    • USCo carries out SR&ED Directly
    • USCo contracts with Canadian Subsidiary
    • USCo contracts with a CCPC
  • Acquisition Structures:
    • Exchangeable Share Structure