Subsidiary, ULC, branch or treaty-based filing? Learn how each option affects tax, liability and repatriation, and when no Canadian income tax applies at all.
This course will provide a practical overview of key tax considerations for businesses expanding into Canada, focusing on the choice of entity (corporation, branch, or partnership), and the implications of federal versus provincial incorporation.
We will outline the steps for registering with the Canada Revenue Agency, including obtaining a business number and setting up GST/HST, payroll accounts and other accounts, and discuss compliance requirements for each. The session will also address cross-border financing strategies, with particular attention to Canada’s thin capitalization rules that limit interest deductibility on related-party debt, as well as the impact of withholding taxes on payments to non-residents.
Additional topics will include:
The importance of transfer pricing compliance
The treatment of paid-up capital and repatriation of funds
Best practices for structuring operations to optimize tax efficiency and minimize risk
Attendees will gain actionable insights to help clients navigate the complexities of establishing and operating a business in Canada while ensuring compliance with Canadian tax laws.
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AJAG Professional Development was founded in 2003 with a mission of making professional development easier and more cost-effective for Canadian accountants and other financial advisory professionals. Our comprehensive range of flexible and reasonably-priced courses, programs and seminars are delivered online and in classroom-style settings in the Greater Toronto Area (Toronto, Oakville and Markham). AJAG features a roster of highly-qualified instructors who deliver content that is pertinent, up-to-date and engaging.

Tax Partner @ McGovern Hurley LLP | CPA, Tax Expertise
John leads the Tax Advisory Group at McGovern Hurley, bringing over 15 years of specialized expertise in cross-border and international tax. Renowned for his strategic insight, John advises private and publicly listed entities on complex tax matters, helping clients navigate global tax regimes and optimize their financial structures. His practice focuses on cross-border transactions, international tax planning, and corporate structuring, ensuring compliance and efficiency. Before joining McGovern Hurley, John built his expertise at a mid-sized Toronto firm, followed by five years specializing in real estate taxation at a national firm. Today, he’s a trusted advisor to Invest in Ontario and Toronto Global, guiding global businesses expanding into Canada with his cross-border tax acumen.