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