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QUESTION:
What are the tax implications for moving "mind & management " of a Canadian company to its US parent as well as making sure "arms length " rules are still being followed ... What are the tax implications of a resident in Canada and non resident in Canada ? from my readings of the laws it appears that quotations , importation of products , sale of products and risk are part of the definition of "carrying on a business " in Canada ..your comments would be appreciated in light of the US parent wanting to become more in control of the Canadian subsidiary and the lines are becoming blurred as to where the "mind & management" residency will be ...what are the downsides of losing "mind & management" ?
Thanks & Regards,
XXXXXXXXX
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david ingram replies:
This question is beyond the scope of the Q & A's answered.
The line is pretty black and white in retrospect and pretty blurred as you approach it.
However, in general in my opinion, there is no down-side to losing mind and management for the American company, only for the people working in the company. It is a usual precursor to the Canadian employees being downsized in salary authority and numbers.
If someone else has a dissertation on the subject and would like to pass it on, I would be glad to distribute it.
Sonja Clark in the West Vancouver Office is a CA, CPA and has a law degree as well as experience working in Oregon and BC. You might want to buy an hour's time to discuss it (604) 980-0321.
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