Canada Revenue Agency Reporting Requirements
A Canco which controls a Forco will have an obligation to submit certain special returns to the Canada Revenue Agency annually.
Failure to file such returns on a timely basis will expose Canco to significant penalties.
Form T1134
Any Canadian resident, whether a corporation or individual, with respect to which there is a “foreign affiliate” (“FA”) in a taxation year, must file form T1134 within 15 months after the end of that year with the CRA. An exception applies in connection with “dormant” FAs.
This form provides detailed information regarding the corporate structure in relation to FAs, including ownership percentages. In addition, the form requires disclosure of various information regarding the various sources of income earned by the FA in the year,
If a Canadian resident has more than one FA, only one Form T1134 should be filed by that taxpayer. The T1134 will have separate supporting schedules for each FA.
The T1134 reporting for interests in FAs is in lieu of any requirement to report such interests on the more general “Foreign Property” reporting form (T1135).
Accordingly, Canco will need to file form T1134 with the CRA annually in connection with its interest in Forco.
Form T106
A Canadian resident that has more than $1,000,000 in business-related transactions with non-residents with which it does not deal at arm’s length is required to file form T106 with the CRA each year by its normal filing due date.
Accordingly, if Canco has transactions that total more than $1,000,000 with Forco, or any other non-arm’s length FA, form T106 must be filed.
This form provides detailed information on the nature of such transactions, as well as some information on the transfer pricing methodology that is used.
CANADA-BASED INTERNATIONAL TAX CONSULTING FOR CLIENTS WORLDWIDE
100% Dedicated To Minimizing Worldwide Tax Liability
Do you have a challenging international tax problem involving Canada?
Michael Atlas is widely regarded as one of the leading international tax experts in Canada.
He advises clients worldwide via email, phone, or Skype. You would never have to travel to his Downtown Toronto office.
Michael Atlas’ practice is strictly devoted to high-level tax CONSULTING. He does NOT provide accounting or tax preparation services.
RELYING ON THIS GUY’S ADVICE CAN BE DANGEROUS!
Joseph Blow, CPA, Average Accountant
Contrary to what most people think, very few Canadian accountants are real tax experts. Regardless of whether they have a designation (like CA,CGA,CMA, or CPA) or not, the vast majority have only a general knowledge of tax law and practice. That is fine for preparing tax returns, or giving advice on basic routine issues. However, when it comes to complex, unusual matters, very few have what it takes to give proper advice. When it comes to international matters, even most accountants who specialize in tax don’t have the ability, and go to an expert like Michael Atlas.
IN LESS THAN 5 MINUTUES HE CAN USUALLY HELP!
Michael Atlas, CPA,CA,CPA (ILL), TEP
That’s right, in less than five minutes from the time that Michael Atlas gets your email message or phone call, he can typically suggest an approach to help with a high-level international tax problem!
Because of Michael Atlas’ unique creative abilities, 40+ years of wide-ranging experience, and encyclopedic knowledge of Canadian tax law, he is uniquely equipped for situations where FAST RESPONSE is demanded.
Why don’t you put him to the test-you have nothing to lose!
Phone (Office): 416-860-9175
Mobile (After-hours): 416-949-7111
Email: matlas@TaxCA.com
michael.atlas3
All information provided is TOTALLY CONFIDENTIAL.
YOU NEVER HAVE TO LEAVE YOUR OFFICE!
Wherever you are in the world, you can get complete advice from Michael Atlas without having to leave your home or office.
He has been providing complete advice to clients worldwide via email for over 25 years! Phone or Skype works fine too! However, if you happen to be in Toronto, and want to meet, no problem!
WANT TO REMAIN ANONOMOUS?-NO PROBLEM!
All information provided to Michael Atlas remains strictly confidential, as is consistent with the Rules of Professional Conduct of the Institute of Chartered Professional Accountants of Ontario.
However, even with that, some clients wish to remain anonomous. No problem! Michael Atlas can give advice to Mr. or Ms. “X”-he does not need to have a real name. He can just give advice based on hypothetical facts as presented to him.
ADVISING ON A WIDE-RANGE OF ISSUES
Michael Atlas provides FAST, imaginative and creative advice in connection with the following, as well as many, many more areas:
- Emigration from Canada-guidance on saying “goodbye” to Canadian taxes
- Immigration to Canada-planning to minimize exposure to Canadian taxes
- Returning Canadian expats-what to do about assets accumulated offshore
- Offshore trusts-when can you use them and when you cannot
- Offshore corporations-you can save a fortune in the right situation
- International business structures-proper planning is the key to saving taxes
- Using tax treaties-they can be your best friend!
- Planning foreign income-proper planning is the key!
- Tax disputes and objections– he has a great track record in beating the CRA!
The human organism has sophisticated detoxification system and this is the ingredient that levitra vardenafil generic works against the PDE 5 enzyme and helps in getting erection. But in case of oral jelly or other products by Ajanta Pharma need to be taken after consulting usa generic viagra a doctor. Iatrogenic – buy tadalafil uk Adverse effects of certain medicine affect an erection. Sildenafil citrate is available in the same extents in the non specific viagra soft , Suhagra, and the first levitra.
Contact Michael Atlas now to get FAST advice on all of these areas and more!
THE ONE OF A KIND CANADIAN INTERNATIONAL TAX BLOG
Michael Atlas authors a unique Blog that is totally devoted to Canadian international tax issues. It is the only one of its kind in the world! It now has 108 original articles.
Thousands of readers access its pages every month.
You may read all the pages of the Canadian International Tax Blog through the Blog page of this site.
THE OUTSTANDING CANADIAN BOOK ON NON-RESIDENT TAX
Michael Atlas is widely known across Canada for being the author of the leading book Canadian Taxation of Non-Residents, which is published by Wolters Kluwer (formerly CCH Canadian Ltd). This highly popular book, which is now in its 5th Edition, has been regularly used as a reference by accountants and lawyers in all parts of Canada for over 20 years! (To learn more about, or order, this book, click here.)
He can advise on all issues relating to non-resident taxation, including how to become a non-resident; all the implications and requirements; dealing with Canadian source income; and what to do if a Canadian expat returns.
FAST ADVICE ON DOMESTIC TAX PLANNING TOO
Michael Atlas can also provide FAST advice on a wide-range of high-level domestic tax issues, including
- Estate planning
- Real estate
- General corporate and business tax issues
- Corporate reorganizations
CONTACT MICHAEL ATLAS NOW TO GET FAST ADVICE!
You should contact Michael Atlas now for a FAST evaluation of whether and how he can help you. There is no cost or obligation.
Phone (Office): 416-860-9175
Mobile (After-hours): 416-949-7111
Email: matlas@TaxCA.com
michael.atlas3
All information provided is TOTALLY CONFIDENTIAL.