International Tax

International Tax Compliance and Advisory Services

In today’s global economy, managing international tax compliance and structuring cross-border transactions are critical to business success. At Andersen in Canada, we offer customized solutions designed to help you navigate Canada’s complex tax rules. Supported by a team of experts with deep technical knowledge and extensive practical experience, we work closely with you to address your specific needs.

Advisory Services in an International Context

We provide strategic guidance to help you navigate cross-border tax challenges effectively.

Our Areas of Expertise Include

Digital Services Tax (DSTA)

The Federal Government introduced the Digital Services Tax Act (DSTA), effective retroactively from January 1, 2022, which levies a 3% tax on revenues exceeding CAD $20M from taxable digital services provided to Canadian users.

At Andersen in Canada, we help businesses engaged in digital activities assess their revenue streams, manage DSTA implications, handle registration, and meet filing and payment obligations.

OECD Pillar 2 Model Implementation

The Global Minimum Tax Act (GMTA), effective for fiscal years starting on or after December 31, 2023, enforces a 15% global minimum tax rate.

As part of Andersen Global, we provide unparalleled expertise to:

Structuring

We assist in optimizing the legal structures of Canadian entities to achieve favorable tax outcomes, whether for repatriation or dismantlement, while ensuring compliance with Canadian tax requirements and reducing exposure.

Financing

We design optimal capital structures, ensuring compliance with Canada’s thin capitalization rules, Excessive Interest and Financing Expenses Limitation (EIFEL), and other anti-avoidance provisions.

Foreign Affiliates’ Tax Attributes

We monitor and manage tax attributes related to foreign affiliate investments, including surplus calculations, adjusted cost base computations, and paid-up capital tracking.

Foreign Affiliate Dumping (FAD) Rules

We assist Canadian subsidiaries of foreign multinationals in navigating rules that limit tax benefits derived from certain foreign affiliate investments.

Tax Treaty Management

Leveraging Canada’s extensive tax treaty network, we help mitigate withholding tax exposure and ensure compliance with treaty provisions and domestic anti-avoidance rules.

Foreign Accrual Property Income (FAPI)

We provide guidance on the taxation of passive income earned by foreign affiliates, ensuring compliance with FAPI regulations.

Hybrid Mismatch Rules

We help you navigate the complexities of hybrid mismatch rules, addressing differing tax treatments of entities and financial instruments across jurisdictions.

Canadian Tax Compliance for International Transactions

Cross-border transactions often involve specific reporting obligations. We help businesses meet their compliance needs efficiently through:

T106 Information Return

Reporting cross-border related-party transactions while ensuring compliance with Canada’s transfer pricing rules.

T1134 Return

Managing compliance for interests held in foreign affiliates of Canadian entities.

Treaty-Based Returns

Filing treaty-based returns to secure benefits for non-residents and cross-border entities.

NR4 Slip

Reporting payments made to non-residents while meeting Canadian withholding tax obligations.

T4A-NR Return

Assisting with the reporting of payments for services rendered physically in Canada by non-residents.

Why Choose Andersen?

With decades of experience in international tax structures and transactions, combined with cutting-edge knowledge of the Canadian Income Tax Act and Canada’s tax treaties, Andersen in Canada is your premier partner for international tax advisory.

Our Professionals in International Taxation

Steven Flynn, CPA, CA, CPA (Washington)

Vancouver

Partner

Dale Franko

Calgary

Partner

Danny Guerin, CPA, CA, LL. M.Fisc.

Montreal

Partner

Shan Lu, CPA, IRS Enrolled Agent

Vancouver

Director, Tax

Philip Mei, CPA, CGA, CPA (New Hampshire), TEP

Calgary

Partner

Paula Owen, CPA, CA, EA, TEP

Calgary

Partner

Krista Rabidoux, CPA, CMA, FEA

Calgary, Edmonton

Partner

Omar Yassine, CPA, D.Fisc.

Montreal

Senior Manager

Our detailed knowledge of the Canadian Income Tax Act ("ITA") and the applicable Canadian tax treaties (as well as the current Tax Information Exchange Agreements "TIEAs") ensures tailored support with high added value.