Canada Cross-Border Tax.
Canada-side cross-border tax planning: residency cessation, deemed-disposition planning, FAPI, trust taxation, and the information-reporting regime.
Residency cessation analysis
Determining the date residency ceases under the Income Tax Act and the relevant treaty tie-breaker rules.
Deemed-disposition planning
Section 128.1 deemed dispositions on emigration, election to defer tax, and security posting strategy.
Pre-departure restructuring
Asset realization, trust collapses, and entity reorganizations sequenced before departure to optimize the deemed-disposition base.
Foreign Accrual Property Income (FAPI)
CFA determination, surplus account tracking, FAPI inclusion rules, and active-business exclusions for Canadian-resident shareholders.
International trust taxation
Section 94 deemed residence, resident-contributor / resident-beneficiary rules, and distribution planning for non-resident trusts.
T1134, T1135, T1161 & T1243 reporting
Information reporting for foreign affiliates, specified foreign property, and emigrating taxpayers.
Continue across Cross-Border Tax
01 / 03US Cross-Border Tax
US-side cross-border tax planning across ECI, FDAP, PE, CFC, and PFIC regimes, plus estate, trust, and pre-immigration positioning for globally mobile clients.
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02 / 03Panama Cross-Border Tax
Panama-side cross-border tax planning under the territorial principle: source-of-income analysis, pre-arrival positioning, holding architecture, and special regimes.
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In closing
Let’s talk.
A single conversation usually clarifies more than a month of research. We engage on a value basis, and every introduction begins with a direct, confidential exchange.
We advise on
- 01Cross-Border Tax
- 02International Corporate Advisory
- 03Multi-jurisdictional Asset Structuring
- 04Panama Relocation
Rothbard Group S.A.
A boutique cross-border tax and corporate advisory firm. Licensed U.S. Enrolled Agent authorized to practice before the Internal Revenue Service.