International tax

As corporations are increasingly expanding across borders, changes in domestic and international tax laws can affect tax planning strategies. KPMG’s international tax professionals understand these changes and help businesses, operating in Canada and around the world, comply with domestic and international tax laws with reliable tax planning advice built on years of experience. KPMG tax professionals offer international tax services tailored to your business. Prepare for, adapt and respond to tax changes, mitigate risks, and gain a competitive edge with the help of KPMG.

Inbound/outbound international transactions including cross-border mergers, acquisitions, and dispositions

When considering or undertaking cross-border mergers, acquisitions, and other reorganization opportunities, the associated tax implications can be challenging to navigate. KPMG’s international tax advisors can help your organization manage all aspects of cross-border reorganization opportunities to increase value and mitigate risks.

Tax due diligence for international M&A transactions

KPMG’s international tax team can assist in undertaking the appropriate due diligence to ensure potential risk areas are not overlooked. Tax due diligence allows for more informed purchasing decisions and facilitates price negotiations and determination of the deal structure.

International corporate tax advisory – tax-efficient structuring of inbound and outbound investments and global financing

KPMG’s international tax team can help structure inbound and outbound investments in the most advantageous way while managing compliance requirements in every jurisdiction. Our international tax team can also review your existing structure and provide recommendations on how to improve efficiency and effectiveness.

Foreign reporting and related surplus calculations

The CRA requires annual surplus computations to support dividend deductions taken in Canada. Surplus pools reflect the economic earnings of a foreign affiliate and can help in determining the Canadian tax treatment of dividends, capital gains, upstream loans, acquisition/corporate reorganizations, and safe income calculations. KPMG’s web-based Surplus Calculator makes the annual task of preparing surplus computations simple and seamless.

Form T1134, “Information Return Relating to Controlled and Not-Controlled Foreign Affiliates” includes additional questions and more detailed requests. The KPMG international tax team can help you complete this form to ensure compliance with foreign affiliate reporting rules. Our end-to-end technology solution can assist with the collection, management, and transformation of the expanded data required to complete these forms.

When Canadian businesses hold shares in foreign investments for non-registered accounts, any income, dividends, and capital gains arising from the investment must be reported on Canadian corporate income tax returns. Determining the amount to include on the tax return is not a simple task, as you must consider currency conversion, double taxation by the foreign country, and the different rules for amounts over $100,000. The KPMG international tax team can help manage these issues, as well as other risks, and help determine the best strategies when it comes to investing in registered accounts such as RRSP or RRIF.