Crypto for corporations — how much of this can I do myself?
Some of it, yes — and we will say so on the call if that is the honest answer. The parts that are worth paying for are the ones where a missed election, a missed deadline or an unverified threshold costs more than the fee: corporate holdings raise questions of inventory versus capital property, foreign-property reporting where the custodian is abroad, and how gains are eventually distributed to shareholders.
What if I have already filed and got it wrong?
That is a common starting point. We re-derive the position, identify whether an amendment or a disclosure route is the right vehicle, and tell you which one preserves the relief that is still available. The order matters more than the speed.
How long will it take?
It depends on the documents rather than on us. Once the pack is complete most filings turn around inside a fortnight; anything that needs a certificate from a tax authority runs on that authority's timetable, which we tell you at the start rather than at the end.
How is a corporation's crypto holding taxed differently than an individual's?
A corporation's crypto activity is assessed against its ordinary business, so whether a holding is treated as inventory, a capital property, or a hedge against operating currency depends on why the company holds it and how that fits its stated business activity. The accounting treatment the company adopts also feeds into the tax position, so the two need to be considered together rather than separately.
Does accepting crypto as customer payment create a separate tax event?
Yes. Accepting crypto as payment is treated as a sale of goods or services at the value of the crypto received, and a separate disposition event can arise later if the corporation holds that crypto before converting it. Two things happen at once — revenue recognition on the sale and a potential gain or loss on the crypto itself — and both need tracking from the point of receipt.
Do cross-border corporate groups need a policy for allocating crypto activity?
If more than one entity in a group transacts in or holds crypto, the group needs a consistent policy for which entity records which activity and how any intercompany transfers of crypto are priced, since an inconsistent approach across jurisdictions invites scrutiny from more than one tax authority at once. We help design that policy alongside the group's existing transfer pricing approach.
What is FAPI, and how does it differ from GILTI?
Canada's foreign accrual property income taxes a Canadian shareholder currently on the passive income of a controlled foreign affiliate — interest, rent, royalties, certain gains — with a deduction that recognises foreign tax already paid on it. GILTI comes at the problem from the opposite side: it targets active income above a return on tangible assets. A group with both a Canadian and a US shareholder can therefore be inside both regimes on different slices of the same profit. See GILTI against FAPI.
What is a foreign trust for US tax purposes?
A trust that is not a domestic trust — broadly, one that fails the tests looking at whether a US court can exercise primary supervision and whether US persons control the substantial decisions. The classification decides everything downstream: whether the settlor is taxed on the income as owner, how distributions to US beneficiaries are taxed, and which annual information returns are due. Many ordinary foreign arrangements, including some pension and education savings vehicles, land inside the definition. See Form 3520-A.
