Course: Channeling Income Outside of Canada

This course is from the 2015/2016 series

 

Topics to be covered include: 

  • The basic structure for earning business income offshore.
  • The importance of tax treaties and ‘Tax Information Exchange Agreements”.
  • Attractive offshore jurisdictions in which to earn business income.
  • Impediments to channelling investment income (FAPI) offshore.
  • Types of income that appear to be FAPI but are classified as business income and vice versa.
  • Ensuring that offshore corporations are not considered to be resident in Canada.
  • The treatment of dividends received from offshore corporations.
  • The concepts of “foreign affiliates” and “controlled foreign affiliates”.
  • Offshore trusts.
  • Offshore investment funds.