Neufeld Legal P.C. - Toronto . Calgary . New York City

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Taxes play an important role in the global economy, and as such have become a necessary evil in the corporate business world. For whereas every business must pay its requisite tax liability, there is nothing that requires a company to pay in excess of what the law requires. As such, structuring one's business operations and commercial transactions to minimize taxes, when done in compliance with applicable laws and regulations, is an intelligent exercise in business and financial management.

Meeting this challenge, such that your company remains compliant with pertinent tax laws, regulations and legal interpretations thereof, while optimizing its profitability, is an undertaking that should be pursued in conjunction with knowledgeable tax lawyers who are committed to the dual pursuits of strict legal compliance and permissible tax minimization strategies. Attempting to undertaking tax structuring that is not compliant with the law is a recipe for disaster and should not be the route of any business.

The reality is that tax authorities the world-over are becoming increasingly effective in detecting and pursuing deceptive and illegal tax-related activity, with the penalties being significant and the disposition of those misappropriate tax savings making it exceedingly difficult to repay those tax authorities the taxes that are owing, together with interest and penalties. As such, tax compliance needs to be an integral component of corporate tax strategy.

Neufeld Legal P.C.

At Neufeld Legal P.C., we work with corporate businesses to optimize, strategize and implement both long-term and transactional tax planning; however, we do not undertake tax litigation or tax disputes. Our legal team works on proactive tax measures, as opposed to reactive tax matters where previously developed and implemented tax matters come under legal scrunity by the relevant tax authorities.

To learn how we can be of assistance, contact Neufeld Legal P.C. by telephone at 416-887-9702 (Toronto + Ontario) or 403-400-4092 (Calgary + Alberta); email at; or Skype at Christopher.Neufeld.

Taxes Covered - US Canada Tax Treaty
1. This Convention shall apply to taxes on income and on capital imposed on behalf of each Contracting State, irrespective of the manner in which they are levied.
2. Notwithstanding paragraph 1, the taxes existing on March 17, 1995 to which the Convention shall apply are:
(a) in the case of Canada, the taxes imposed by the Government of Canada under the Income Tax Act; and
(b) in the case of the United States, the Federal income taxes imposed by the Internal Revenue Code of 1986. However, the Convention shall apply to:
(i) the United States accumulated earnings tax and personal holding company tax, to the extent, and only to the extent, necessary to implement the provisions of paragraphs 5 and 8 of Article X (Dividends);
(ii) the United States excise taxes imposed with respect to private foundations, to the extent, and only to the extent, necessary to implement the provisions of paragraph 4 of Article XXI (Exempt Organizations);
(iii) the United States social security taxes, to the extent, and only to the extent, necessary to implement the provisions of paragraph 2 of Article XXIV (Elimination of Double Taxation) and paragraph 4 of Article XXIX (Miscellaneous Rules); and
(iv) the United States estate taxes imposed by the Internal Revenue Code of 1986, to the extent, and only to the extent, necessary to implement the provisions of paragraph 3(g) of Article XXVI (Mutual Agreement Procedure) and Article XXIXB (Taxes Imposed by Reason of Death).
3. The Convention shall apply also to:
(a) any taxes identical or substantially similar to those taxes to which the Convention applies under paragraph 2; and
(b) taxes on capital;
which are imposed after March 17, 1995 in addition to, or in place of, the taxes to which the Convention applies under paragraph 2.

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