Areas of Practice

Areas of Practice

Over the years, Michael Atlas has assisted in connection with thousands of different tax issues. Listed below is a sample of the most common types. Michael Atlas does not, except in very rare circumstances, provide tax compliance services, such as preparing tax returns. However, he can refer consulting clients to other accounting firms in his network that will provide such services.

In-bound International Tax

  • Tax planning for immigration to Canada
  • Tax planning for returning Canadian expatriates
  • International corporate tax planning Canada
  • Investment in Canadian businesses and real estate by non-residents
  • Non-residents carrying on business in Canada
  • Canadian subsidiaries of foreign corporations
  • Tax treaty issues

Out-bound International Tax

  • Tax planning for emigration from Canada
  • Post-emigration expatriate issues
  • Investment by Canadians in foreign businesses and corporations
  • Offshore tax planning and the use of tax havens
  • Investments by Canadians in foreign real estate
  • Tax issues re offshore trusts

Estate Planning

  • Estate “freezing” of private corporations so that tax on death is minimized
  • Reviewing and advising on wills in order to avoid tax pitfalls and minimize taxes payable on death
  • Advising in connection with the formation and terms of family trusts created during the lifetimes of individuals
  • Planning aimed at minimizing exposure to probate fees on death
  • Planning aimed at minimizing exposure to U.S. estate taxes
  • Post-mortem planning aimed at avoiding double taxation in connection with shares of private corporations owned on death
  • Planning issues re corporate-owned life insurance
  • Structuring shareholder buy/sell agreements

Real Estate

  • Ownership structures re acquisition of real estate
  • Minimizing or deferring tax on real estate gains
  • Maximizing utilization of tax losses
  • Structuring joint ventures or syndications
  • Capital gain versus income determinations
  • Principal residence issues
  • Non-resident investment in Canadian real estate
  • Canadian investment in foreign real estate
  • Creditor proofing real estate holdings

Corporate & Business Tax Issues

  • Mergers and acquisitions
  • Corporate reorganizations
  • Incorporation of unincorporated businesses
  • Minimizing tax on the sale of shares of corporations by using the “capital gains exemption”
  • Minimizing tax on the sale of shares of corporations by using “safe income strips”
  • Utilizing corporate tax losses
  • Partnership formation, reorganization, and dissolution
  • Optimizing dividend/salary policy
  • Maximizing the use of the “small business deduction”
  • Rolling over shares to holding companies
  • Creditor proofing reorganizations
  • Structuring shareholder buy/sell agreements
  • Advising re foreign corporations operating in Canada
  • Advising re Canadian corporations operating outside of Canada