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 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


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