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 provide tax compliance services, such as preparing tax returns.
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
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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