Cross-border M&A transactions present unique opportunities and challenges under Canadian tax law, especially when integrating with international structures. At Alexander Tax Law, we guide clients through these deals with a focus on tax-efficient strategies.
In Canada, tax rules for cross-border M&A emphasize deferred transfers and amalgamations where conditions are met, allowing for tax-neutral rollovers in qualifying acquisitions. Key considerations include withholding taxes on payments to non-residents, foreign tax credits, and compliance with treaties like the Canada-U.S. Tax Convention.
For U.S. acquirers of Canadian targets, the absence of tax consolidation means losses can’t be shared across groups, requiring careful structuring to optimize post-acquisition tax positions. Additionally, enhanced information exchange under agreements like FATCA impacts reporting for financial institutions involved in deals.
From due diligence to closing, integrating tax planning early can mitigate risks such as double taxation. In my practice, I’ve assisted with numerous cross-border deals, ensuring clients achieve practical results.
Alexander Tax Law provides boutique precision for your M&A needs. Contact us to discuss how we can support your international transactions.