Stop letting the computer drive your tax compliance and master the technical rules behind foreign tax credit calculations.
Foreign tax credits are a frequent source of frustration for tax advisors. The rules are complex, the consequences of error are significant, and the Canada Revenue Agency continues to closely scrutinize large and recurring foreign tax credit claims. This presentation focuses on the areas where practitioners most often encounter risk, uncertainty, and missed planning opportunities.
Key topics include:
a) A focused review of the most important elements of section 126 of the Income Tax Act
b) The distinction between business income tax and non-business income tax, and why the classification matters
c) The impact of the foreign tax credit rules on former residents of Canada
d) The section 110.5 election, which allows a corporation to increase taxable income to maximize deductible foreign tax credits without increasing certain other federal deductions or credits, while also increasing the corporation’s non-capital loss
e) Deductions available under section 20 for foreign taxes paid
f) The role of tax treaties in shaping foreign tax credit outcomes
g) Foreign tax credit planning strategies and common pitfalls
h) Selected CRA views and administrative guidance that provide insight into how claims are reviewed
i) The interaction between foreign tax credits and U.S. business structures
This session is designed to help practitioners move beyond mechanical compliance and develop a practical understanding of how foreign tax credit rules operate in real-world files. By highlighting high-risk areas, current CRA thinking, and targeted planning techniques, the presentation equips advisors to reduce reassessment exposure, strengthen foreign tax credit claims, and deliver more confident advice to clients with cross-border activities.
1 activity • 1 videos • duration: 2h 16m
Tax Structuring, Planning & Reporting
At CPA Solutions we provide services throughout the cycle of a tax transaction from setting up creative domestic or cross border structures to implementing those structures and finally reporting them on the tax returns. Our knowledge of Canadian and US taxation coupled with an understanding of the accounting concepts enables us as a practitioner to provide a complete overall service to achieve our clients needs. We strive to only enhance your practice in ways a larger firm can achieve through their in-house tax department.
CPA, TEP, Mtax, BSc(Hons)
Manu has over 20 years of experience in taxation in both domestic and international, personal and corporate taxation as well as litigation support. He runs his own independent tax practice with offices in Montreal and Toronto with a team of professionals consisting of tax lawyers and tax accountants. His firm services a diverse client base which includes manufacturing, retail and distribution, construction, farming, real estate, athletes and artists, across Canada and the US. His firm acts as a counsel to over 125 professional firms in Canada and USA specializing in domestic and international reorganizations and transactions. Manu is known as one of the leading experts in Section 55 of the Act and butterfly reorganizations. He is an award winning and prolific tax writer. His Master of Taxation thesis on butterfly reorganizations won 2 awards and was published in the Canadian Tax Journal. Manu has published and presented over 450 tax articles and presentations since 2001 across Canada. Manu is an authority in taxation as his name has been cited 41 times in the Income Tax Act. Manu has taught tax at The Canadian Institute of Chartered Professional Accountants, The Canadian Tax Foundation and The Society of Trust and Estate Practitioners, of and various provincial accounting bodies across Canada. Manu has sat or sits on the Steering Committees for the Canadian Institute of Chartered Professional Accountants’ National Conference on Income Taxes; the Canadian Tax Foundation Laval Program Committee; CPA Canada's Small and Medium Practitioner’s Tax Committee; and the Canadian Tax Foundation's Ontario Tax Conference. Manu served a three-year term from 2016-2019 on the Canadian Tax Foundation’s Board of Governors.
Partner at CPA Solutions LLP
Boris has over 17 years of experience in public practice. Before becoming a partner at CPA Solutions LLP, Boris worked as a senior tax manager in the private enterprise group at one of the big four national firms. Boris has vast experience working with owner-managers and their small, medium, and large private corporations across industries. In addition, Boris is also involved in the tax community through the facilitation of the In-Depth tax courses, facilitation of tax week under the former School of Accountancy and through presenting on various tax topics at YDCPAA, PD Consortium and AJAG.
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