EVERYTHING COUNTS

Corporate Tax • Indirect Tax • International Tax • Tax Controversy • SR&ED

International Tax

U.S. CORPORATE TAX PLANNING

Whether you are a business already operating in the U.S. or are looking to start doing business in the U.S., it’s important to understand all the tax implications so you can strategically plan and manage your tax liability. Our experienced international tax team includes professionals who practice in both Canada and the U.S and understand U.S. federal and state tax laws from a Canadian perspective.

Working closely with you, we deliver a full suite of tax planning services, including:

> Tax planning and structuring > Cross-border financing and structuring > Acquisition and divestiture planning > State and local tax planning > Audit defence – negotiating with the IRS and

state tax authorities > Remedial tax planning – assistance where there are past

inadvertent > Mitigating tax exposures

U.S. CORPORATE TAX COMPLIANCE

If you are doing business in the U.S., you are required to file U.S. income tax and information returns. Foreign-based companies may also have additional filing requirements, even if the activities are limited. Failing to comply could result in onerous tax penalties. MNP will help assess your filing obligations and manage the compliance process to ensure you are complying with the current U.S. federal and state tax legislation.

Our tax compliance services include:

> Corporate tax compliance – federal and state level income tax preparation

> Sales and use tax compliance – federal and state level tax preparation

> Business information reporting – federal and state level > Foreign and cross-border transaction reporting > Advisory – Canadian and U.S. consequences of specific

business transactions, conducting historical earnings and profits (E&P) studies and identifying opportunities relating to available elections

In today’s international business environment, tax requirements and legislation are becoming increasingly complex, which can leave multinational businesses struggling to keep up. Many businesses also face a heavy burden on business profits and capital gains with global tax costs that are excessive and disproportionate. To ensure you pay the least amount of tax possible, it’s important to work with experienced professionals who understand the legislation of various countries and are familiar with the requirements of international business. That’s where MNP can help.

MNP’s International Tax Services team has extensive experience helping businesses in Canada, the U.S. and other foreign jurisdictions address their cross-border needs, by delivering customized services in the following areas:

> U.S. corporate tax planning > U.S. corporate tax compliance > Transfer pricing > Cross-border tax services (inbound & outbound) > Expatriate tax

Whether you or your employees are moving to or from Canada permanently or accepting a temporary assignment abroad, effectively navigating Canadian and foreign country tax laws can be daunting. In addition to tax planning issues, jurisdictional compliance requirements are becoming more extensive — along with the fines and penalties for failing to meet those requirements. To mitigate your risk, it’s important to work with experienced professionals. MNP has extensive experience providing businesses and their employees with taxation advice regarding domestic and foreign assignments no matter where their business takes them.

Our expatriate taxation services include:

> Employer tax advice and planning

> Employee tax advice and planning

> Tax compliance for global income tax and payroll filings

> Pre-immigration tax planning

> Cross-border family wealth planning

THE RIGHT ANSWER FOR INTERNATIONAL CORPORATE TAX SERVICES

EXPATRIATE TAXATION

CROSS-BORDER TAXATION

Many businesses are looking to expand beyond their domestic borders into new markets. While this creates exciting business opportunities, it can also be very complex from a tax perspective. Whether you are a Canadian company doing business abroad, or a foreign company doing business in Canada, MNP can assist you with your international and domestic tax needs.Outbound from CanadaOur cross-border outbound taxation services include:

> Tax planning and advisory services > Cross-border and international tax structuring > Acquisition and financing of operations > Impact assessments of tax treaties on your business structure > Ensuring the efficient repatriation of profits back to Canada

Inbound to CanadaOur cross-border inbound taxation services include:

> Tax planning and advisory services for establishing business in Canada > Canadian corporate tax compliance – federal & provincial > Indirect tax planning and advice on indirect tax implications > Ensuring tax efficient repatriation of profits back to foreign country > Develop tax efficient corporate structures for Canadian operations

MNP is an independent member of Praxity, AISBL, which is a global alliance of independent accounting firms. As one of the largest alliances in the world, Praxity strives to be the most advanced alliance of strong, like-minded, independent and committed accounting firms that deliver unmatched client service and quality solutions globally. With more than 100 offices in 72 countries across the globe, MNP is able to draw upon the expertise and international taxation experience of member firms to deliver value-added solutions to our clients.

When it comes to tax, it’s all about the details. Knowing the rules and regulations, what qualifies, what doesn’t and how to structure your business and claims most effectively. Our specialized teams are focussed on every facet of tax. We have the in-depth knowledge and experience that will allow you to capitalize on all the opportunities available. We know what to look for, right down to the smallest details. And it’s the small details that can add up to make a big difference.

TRANSFER PRICING

If you are a Canadian business that intends to sell goods or services outside of Canada or a foreign business transacting in Canada, you need to establish pricing methodologies based on transfer pricing rules in Canada and the foreign country. You will also have to determine, use, and document arm’s length pricing to mitigate the risk of transfer pricing adjustments and penalties. MNP can develop transfer pricing strategies that are practical, defensible and consistent with your overall corporate strategy.

Our transfer pricing services include: > Transfer pricing planning – a review of intercompany transactions and provision of recommendations for transfer

pricing methodologies

> Preparation of transfer pricing documentation

> Assistance with obtaining advance pricing arrangements

> Dispute resolution – audit defence, appeals, competent authority and voluntary disclosures

> Annual compliance requirements – disclosing intercompany transactions with non-resident related parties

GLOBAL ALLIANCE

EVERYTHING COUNTS

Praxity AISBL is a global alliance of independent firms. Organised as an international not-for-profit entity under Belgium law, Praxity has its executive office in Epsom. Praxity – Global Alliance Limited is a not-for-profit company registered in England and Wales, limited by guarantee, and has its registered office in England. As an Alliance, Praxity does not practice the profession of public accountancy or provide audit, tax, consulting or other professional services of any type to third parties. The Alliance does not constitute a joint venture, partnership or network between participating firms. Because the Alliance firms are independent, Praxity does not guarantee the services or the quality of services provided by participating firms.

Visit us at MNP.ca

ABOUT MNP

MNP is a leading national accounting, tax and business consulting firm in Canada. We proudly serve and respond to the needs of our clients in the public, private and not-for-profit sectors. Through partner-led engagements, we provide a collaborative, cost-effective approach to doing business and personalized strategies to help organizations succeed across the country and around the world.

To find out what MNP can do for you, contact your local business advisor or visit us at MNP.ca

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