BOYNECLARKE's taxation group provides a full range of tax services for individual, business, and institutional clients. We also act as consultants to other lawyers who seek our advice on tax issues while keeping their own clients. We serve clients located within and outside of Canada on matters concerning all aspects of taxation including income tax, excise tax, and property tax.

We work with many different structures in advising our clients. For example, we have years of experience working with Unlimited Liability Companies, which are vehicles used to improve repatriation of income back to the United States from investment in Canada.

In particular, we are prepared to help clients with any of the following matters.

Tax Planning

The organization and reorganization of a client’s affairs to minimize tax, including:


• Use of family trusts;
  
• Use of professional corporations;
  
• Estate freezes;
  
• Maximizing the benefit of personal capital gains exemptions;
  
• Reorganization of corporate structures and corporate holdings;
  
• Planning to finance a corporation;
  
• Structuring transactions to utilize losses, deductions, and credits; and
  
• Structuring cross-border transactions to take advantage of international tax laws.
  
  Advising on effective operations to minimize tax, including:
  
  
• Designing compensation arrangements for executives and employees;
  
• Designing structures for the distribution of profits to shareholders;
  
• Planning to issue securities; and
  
• Protecting the preferred tax status of not-for-profit and charitable organizations.
  
  Taking advantage of changes in residence to minimize tax, including:
  
  
• Advice for soon-to-be residents and soon-to-be non-residents;
  
• Utilizing advantageous effects of bilateral tax treaties;
  
• Designing systems for holding Canadian property; and
  
• Designing systems for carrying on business in Canada.
  
  Advising on Tax Consequences of Transactions
  
  Including:
  
  
• Corporate acquisitions and sales of assets and shares;
  
• Buyouts and other purchases;
  
• Inbound and outbound capital investment;
  
• Transfer pricing;
  
• Tax disclosures for public transactions;
  
• Reporting on transactions; and
  
• Excise and commodity tax issues.
  
  Advocacy
  
  We represent and advocate on behalf of clients in matters including:
  
  
• Negotiating and dealing with Federal & Provincial government agencies and tax authorities;
  
• Responding to audit inquires;
  
• Obtaining advance tax rulings;
  
• Preparing assessment appeals; and
  
• Representing clients at all levels of appeal tribunals and courts.
  

Our Advocacy Services are provided by our Business Litigation Team. For more information please refer to the Business Litigation Team section.