Dealing with CRA
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From audit to appeal, understand every stage of the CRA process.
Michael Cadesky and Hugh Woolley cover the key steps in managing CRA interactions, including how to defend deductions, draft objections, and navigate interest, penalties, and privilege issues with clarity and precision.
- Why Consider
- Types of Business Activity
- Beware the Slippery Slope
- U.S. Tax Basics
- U.S. Corporation
- U.S. LLC
- Permanent Establishment (P.E.)
- Nexus
- How to Own U.S. Corporations
- Determine Canadian Status of U.S. Corporation
- Interaction with Canadian Tax (CFA)
- Capital Gains Exemption
- U.S. Estate Tax
- Financing
- Thin Capitalization
- How to Operate the Business
- U.S. Salary
- Income Splitting
- Tariffs
- Issues on Sale – U.S. Corporation
Seminar Snapshot
Many clients exploring a U.S. business presence are unaware of the significant tax considerations involved. Even experienced professional advisors often find the cross-border issues complex, and the most common questions difficult to answer.
That’s why we’ve developed a new program to give you a strong foundation in the Canadian and U.S. tax issues that come with doing business in the U.S.
What we’re seeing: Most clients aren’t looking to leave Canada entirely. Instead, they want to understand how a U.S. presence might help them:
- Reduce tariff exposure
- Structure their business more tax-effectively
- Be closer to the U.S. market
- Increase business opportunities
But there are many misconceptions, such as:
- “If I incorporate in the U.S., the income is only taxable there.”
- “I can capitalize the U.S. company with a big loan and $100 in shares, just like in Canada.”
- “Incorporating in Delaware means no income tax.”
- “I can just transfer my sales to a U.S. corporation.”
The Doing Business in the U.S. course cuts through the confusion and lays out the groundwork for further exploration.
Seminar Length: 2.0 hours
Meet Your Presenters
Michael Cadesky
Michael Cadesky is the managing partner at Cadesky Tax and a committed contributor to the tax and accounting professions since 1980, earning the title of Fellow from CPA Ontario. He is a past governor of the Canadian Tax Foundation, past chair of STEP Canada and STEP Worldwide, and past chair of the CPA Canada Tax Committee for Small and Medium-Sized Enterprises. Michael is also the co-author of 11 books on tax subjects and the author or co-author of numerous papers and articles on Canadian and international taxation.
Dean Smith
As the President of Cadesky U.S. Tax Ltd., Dean has been providing U.S./Canada cross-border planning and compliance for over 30 years. He assists private clients with their personal, corporate, and estate planning needs taking into account the unique challenges of integrating two independent tax systems.
Trusted by CPAs and Tax Professionals across Canada
This is a first time for me as well. Your firm was recommended to by one of my friends. Great source of information.
Thank you Mike, Hugh and team! I enjoyed the practical and realistic solutions to various tax issues.
Thank you ALL for such high quality courses and answering the questions in detail! So glad I found you guys!
Thank you very much for the seminars. They are very informative and helpful.
Thank you for the wonderful presentation, materials, and handling of queries as always.
This is my first time taking the Cadesky Tax Seminars. I am learning a lot and watching archived courses too. You have done a great job. Thank you so much!
I really enjoy your seminar series. Your presentations are extremely thorough and you explain complex tax issues very clearly.
The presentations are relevant. The material is easy to follow. Worked examples are excellent. It is a great value.
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