Category Archives: Offshore corporations

CANADIAN CORPORATIONS CAN REPATRIATE PROFITS OF OFFSHORE SUBSIDIARIES TAX-FREE

Many Canadian corporations form a foreign subsidiary (“Forco”) in zero or low-tax jurisdictions in order to reduce their tax liabilities. This is a strategy that can work as long as the following four elements are present: Forco is not resident in Canada, having regard to common law concepts of corporate residency (“mind and management”). Each… Continue Reading