Canada's thin-capitalization rule has changed. Intra-group loans into Canada must be reviewed if adverse tax consequences are to be avoided. Most importantly, those lenders who accepted the non-deductibility of interest by the borrower must now look to their own tax liability...
Tax Law
Dale & Lessmann LLP offers a broad range of tax services, from structuring foreign investment and corporate mergers and acquisitions to advising on sales and commodity taxes and providing tax planning for personal trusts and estates.
Corporate tax planning – Much of our work involves structuring business arrangements to minimize tax exposure. We devise and implement tax strategies relating to:
- In-bound investments and acquisitions;
- Corporate reorganizations;
- Limited partnerships (LPs) and unlimited liability companies (ULCs);
- Enterprise financing;
- Tax disclosure for public documents;
- Non-resident withholding tax (Part XIII tax and Section 116 tax clearance certificates);
- Personal tax planning relating to business immigration and departure taxes.
Trusts and estates planning
We provide clients with the strategies to maximize inter-generational wealth transfers and integrate this planning with our clients' current business structures and interests.
Tax disputes
We advise clients at all stages of the tax dispute process, from administrative appeal to court challenge.
Sales and commodity tax
Our practice assists clients with all aspects of sales and commodity tax, including land transfer tax (HST/GST/PST/LTT). We have extensive experience dealing with the taxation of goods and services provided or performed by non-residents.
We offer the specialized client-centered service of a sophisticated tax law practice incorporated within a leading business law firm.