High net worth clients require legal services regarding the interpretation of international tax conventions.
Notably, we advise these clients in matters of:
- tax and asset planning strategies for ultra high net worth clients, resident and non-resident of Canada;
- the use of trusts as a tool for asset planning in a Canadian and international context;
- FAPI rules;
- rules on resident and non-resident trusts;
- interpretation of international tax treaties;
- qualification of foreign entities, foreign tax rules and tax treatment of trust structures in jurisdictions outside of Canada (wealth tax, throwback rules, CFC, PFIC, estate tax);
- Canadian and foreign tax compliance of Canadian trust structures.