Canada: SR&ED – Tax Incentives For Startups

The Scientific Research and Experimental Development Program, also known as “SR&ED” (pronounced “shred”), is a federal tax incentive program for businesses carrying out eligible research and development activities. SR&ED can play an essential role in a startup’s financing by extending runway until products or services can be monitized. SR&ED is not just for large businesses; startups have equal access to the program.

SR&ED is administered by the Canada Revenue Agency (“CRA”) and is comprised of […]

By |March 23rd, 2015|

U.S. Tax Implications For Canadians Travelling To The US Including Snowbirds And Students

In the past few months, you may have heard how a U.S. citizen is subject to U.S. income tax on their worldwide income and must file U.S. income tax and foreign disclosure forms, regardless of where they actually live. Did you also know that these same rules can also apply to a non-U.S. citizen if they spend a lot of time in the U.S. for any purpose? This could easily apply to Canadians that […]

By |March 23rd, 2015|

Changes In The French-Luxembourg Tax Treaty

Does the change in the French-Luxembourg Tax Treaty bring an end to tax efficient real estate structuring in France?

The answer is NO.
Actual situation
The actual French-Luxembourg tax treaty is an old treaty which contains a favourable capital gain taxation article. As a result most French real estate acquisitions are structured in the way whereby the French real estate is acquired by a French company which is owned by a Luxembourg holding company. The disposal of […]

By |March 22nd, 2015|