Budget-friendly Investor & start-up visa tax

Investor and start-up visa programmes are designed around capital and business plans, and the tax consequences of the structure used to hold that capital are usually decided by immigration counsel. Ask us about budget-friendly investor & start-up visa tax: call the 24-hour helpline on +1 (416) 619-0068, or request a written fixed quote today.

  • 15+Years of cross-border experience
  • 18,000+Clients served
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE

Secure a fixed quote

Your own file sets the fee. Send it over, and a written quote arrives before anything is prepared.

24-hour helpline: +1 (416) 619-0068
  • 15+ years of cross-border experience
  • Google rating 5.0 out of 5
  • 24-hour helpline: +1 (416) 619-0068
The short answer

Investor and start-up visa programmes are designed around capital and business plans, and the tax consequences of the structure used to hold that capital are usually decided by immigration counsel. Where the investment sits, whether it is held personally or through an entity, and when residency begins all determine the tax outcome.

Who this applies to

  • Family members will arrive on different dates
  • You want to know what the move costs before committing to it
  • You are arriving in, or leaving, a country in the next twelve months
  • You hold appreciated assets on the move date
  • You hold or are surrendering a green card or permanent residence

Most people who need help with investor & start-up visa tax tick at least two of those. If you tick none, we would rather tell you that on a call than take an engagement you do not need.

Two of the firm’s advisers and the team in the open-plan office

Fixed fees for investor & start-up visa tax, agreed up front

What sets the fee on investor and start-up visa tax work is how the investment is held, personally or through one or more entities, and how many countries have a claim on it. A single holding and one arrival date prices differently from a family arriving on staggered dates. Quoted in writing first.

T1135 foreign property filing — fixed-fee price

From $349

fixed, quoted before work starts

The Canadian foreign property statement built on cost amount, in Canadian dollars, across everything the test reaches — including holdings people assume are excluded.
See the full fee page

Individual tax filing

From $349

fixed, quoted before work starts

Returns for people whose tax position did not stay in one country, including the years residence itself is in question.
See the fee schedule

Foreign asset & information reporting

From $349

fixed, quoted before work starts

The information returns that carry the heaviest penalties — foreign accounts, foreign property, foreign affiliates — prepared from one asset list.
See the fee schedule

Corporate cross-border filing

From $999

fixed, quoted before work starts

Corporate compliance for a group that trades or holds assets in more than one country, prepared on both sides together.
See the fee schedule

Catch-up & voluntary disclosure

From $349

fixed, quoted before work starts

Late and unfiled years, sequenced and filed together, with the relief available for the delay identified before the first return goes in.
See the fee schedule

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

Documentation for transactions between related companies: the method, the comparables and the file an authority asks to see.
See the fee schedule

Non-resident & departure filings

From $349

fixed, quoted before work starts

Arrival and departure years priced as one engagement, with the part-year residence position and the assets deemed disposed of on exit.
See the fee schedule

Estate & trust filing

From $799

fixed, quoted before work starts

Trust and estate filings that reach across a border, including the reporting a foreign beneficiary or a foreign asset creates.
See the fee schedule

All published fees on one page — one page, every published fee, nothing quoted as a vague bracket.

What is really being tested

Investor and start-up visa programmes are designed around capital and business plans, and the tax consequences of the structure used to hold that capital are usually decided by immigration counsel.

Where the investment sits, whether it is held personally or through an entity, and when residency begins all determine the tax outcome. Aligning the holding structure with the residency start date is the planning.

Two things follow from that. The first is that the outcome is decided by facts you can arrange and evidence you can keep, rather than by how the return is completed at the end of the year. The second is that sequence matters: the same steps taken in a different order can produce a materially different result, which is why the first conversation is about dates and documents rather than forms.

Thresholds and rates move, and summaries written for last year are not evidence about this one. So each figure in your file is sourced to the issuing authority for the specific year; anything we cannot source, we describe as a mechanism and leave unquantified until it can be confirmed. See also Canadian working in the US — taxes on a tn, h-1b or l-1 and repatriating profits to Canada.

What we actually file

  • A written plan sequenced against the move date
  • Structure reviews for trusts and companies before residence begins
  • Certification of prior-year compliance where a status is being surrendered
  • Residency determinations where a date is likely to be contested
  • Pre-arrival and pre-departure computations and elections

Worked through with figures

Put numbers against it and the shape of the answer is obvious.

A deemed disposition on the day residency ends

A portfolio bought for C$190,000 is worth C$376,200 on the departure day. Nothing is sold. Assume half the gain enters income and assume a 43% marginal rate on it.

A deemed disposition on the day residency ends
ItemAmount
Cost of the propertyC$190,000
Value on the departure dayC$376,200
Accrued gain treated as realisedC$186,200
Amount assumed to enter incomeC$93,100
Tax at an assumed 43%C$40,033

C$40,033 becomes payable in a year with no sale and no cash. That is what makes the departure date a planning variable: losses realised before it, an election to defer payment against security, and defensible valuations for anything private all change this number. The shape of that result holds; the size of it depends entirely on your own numbers and dates.

Illustrative figures, not a client engagement: the amounts are chosen to make the mechanism legible, and the rates and thresholds are assumptions stated for the example only. We confirm every one of them against the issuing authority for your own tax year before anything is filed.

From first call to filed

  1. 1A call to our 24-hour helpline to establish the facts and the dates that matter
  2. 2A written scope and a fixed fee before any work starts
  3. 3Preparation, then a named reviewer's sign-off before anything is filed
  4. 4Filing, then payment — after you have seen and approved the result

What you pay, and when

Pricing works the way it should: a defined scope and a fixed fee agreed in writing before anything starts. If the scope turns out to be larger than we thought, that is a conversation before the work, not a line on the bill. Comparable engagements and their fixed fees are set out on the pricing pages.

  • A 24-hour helpline, +1 (416) 619-0068, before you commit to anything.
  • Your existing accountant keeps the domestic file; we take the cross-border piece, with the boundary in writing.
  • A named reviewer signs off every statutory filing.

Where to go from here

Send us the facts and we will tell you what has to be filed and what it costs. The fastest start is a short call and three things: what happened, when it happened, and which countries are involved. Everything else we can ask for as it comes up.

Read and approved for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. Written as general guidance, not as a recommendation for your situation. Talk it through with us before acting on it.

Business tax advisory, in practice

Readers arrive here searching for business tax advisory, and investor & start-up visa tax is what the page is about. Below: who it catches, what has to be filed, and what it costs — quoted in writing, before anything is done.

Investor and start-up visa programmes are designed around capital and business plans, and the tax consequences of the structure used to hold that capital are usually decided by immigration counsel.

The four phases of the work

  1. Start with a conversation about the facts

    Dates, residence, where the income arose. Fifteen minutes is usually enough to know what applies.

  2. Scope and price, both written down

    You get the scope and the fixed fee together, so there is no question later about what was included.

  3. Prepared by one team, reviewed by a named practitioner

    The same people see both sides of the file, and the reviewer signs their name to it.

  4. Filed, then followed through

    Submission is not the end of the engagement — the queries that arrive afterwards are part of it.

What you are actually buying with investor & start-up visa tax

Factor Legal Quotient Hourly billing model
Pricing A fixed fee, agreed in writing before work starts Hourly, billed as incurred
Experience 15+ years of cross-border work, 18,000+ clients Varies by file
Both sides of the border Prepared together by one team, so relief is claimed exactly once One country at a time, reconciled later
Who reviews it A named practitioner, published on the page Whoever the queue reaches
Where the work happens Our offices in India, the USA, Canada and the UAE Whichever single office you can travel to

Four terms worth pinning down

Treaty shopping
Routing income through a third country to access a treaty rate. Anti-abuse tests are written specifically to identify and deny it.
Schedule FSI
The Indian schedule reporting foreign-source income and the tax paid on it, country by country, from which the foreign tax credit claim is built.
Economic substance
The requirement that an entity have real people, decisions and functions in its jurisdiction. It is built contemporaneously or not at all.
Portability
The election allowing a deceased US spouse's unused exemption to be used by the survivor. It has to be claimed on a return.
investor & start-up visa tax: How we read this one

Where the investment sits, whether it is held personally or through an entity, and when residency begins all determine the tax outcome.

The engagement terms hold no matter what the analysis finds — fee and scope agreed in writing up front, a named reviewer on the output, your approval before the finished work is filed.

The published fees closest to investor & start-up visa tax

The other driver is timing. Advice taken before the residency start date is a planning exercise on paper, while the same investor visa structure reviewed after arrival means unwinding decisions already taken and pricing the work to correct them. Both are scoped and agreed in writing before anything begins.

Foreign asset & information reporting

$349fixed, before work starts

Covers: Disclosure of assets and interests held abroad, built once from a single asset list and filed on every side that asks for it.

See this fee page

Corporate cross-border filing

$999fixed, before work starts

Covers: Corporate returns with foreign income, related-party reporting and cross-border structures, for companies of any size.

See this fee page

The difference a dedicated cross-border team makes

We say early if it is not our work

If a file needs something this practice does not do, you hear that at the start rather than after a bill.

Every figure on a page is traceable

Where a rate or a threshold appears in our writing it names the tax year it belongs to. Where it could not be confirmed, the page describes the mechanism and quotes no number.

The reporting penalties get named early

The heaviest exposure on a cross-border file is usually a disclosure form, not the tax. We identify which ones apply before a deadline turns into a penalty.

Cross-border is the whole practice

International and cross-border tax is all we do — not a sideline next to domestic work. The edge cases on this page are our ordinary Tuesday.

Two of the firm’s advisers at the glass desk in the Delhi office

From first call to filed return

Step 1

The opening call

A first call to map the obligations across every country involved

Step 2

Scope in writing

A single fixed fee covering the whole set, agreed before we begin

Step 3

Prepared and checked

Preparation in the order that makes the relief usable, with a reviewer's sign-off

Step 4

Filed, then supported

You approve the finished work, and we file it

The team at work in the open-plan office

From first document to filed return

  • Step 1: Send what you already have – Slips, statements, prior returns — in any order. We list what is still needed after reading them.
  • Step 2: A fee agreed in writing – Quoted from those documents, before the work starts, and it does not move once you accept it.
  • Step 3: Each side drafted against the other – The returns are built together rather than in sequence, so relief is claimed once and in the right country.
  • Step 4: You approve before it is filed – The finished return comes to you first. Nothing is submitted on your behalf unseen.

Quoted up front, in writing.

Contact Us 24-hour helpline +1 (416) 619-0068

More of the same work, from other angles

Each of these carries its own guide, pricing pointers and FAQ.

The work we do for clients like this

Form T1244 — election to defer departure tax T1244 election defer departure tax — the guide, the FAQ and the fixed fee.
NRI joint accounts and clubbing The full guide to NRI joint accounts and clubbing, with the fee fixed before any work starts.
Family business succession across borders Its own page: family business succession across borders — mechanism, deadlines and published fees.
Indian GST for foreign suppliers Everything on Indian GST for foreign suppliers, at the same depth as this page.
Pillar Two readiness assessment Pillar two — the guide, the FAQ and the fixed fee.
Foreign seller: capital gains and the clearance certificate The full guide to foreign capital gains clearance certificate, with the fee fixed before any work starts.
Non-resident rental income from Canadian property Its own page: non resident rental income tax Canada — mechanism, deadlines and published fees.
Guarantee fee pricing Everything on guarantee fee pricing, at the same depth as this page.
Intercompany agreements Intercompany agreements — the guide, the FAQ and the fixed fee.

Who we help

Management consultants — what we charge Management consultants what we charge — the guide, the FAQ and the fixed fee.
IT contractors — what you owe in each country The full guide to it contractors what you owe in each country, with the fee fixed before any work starts.
Tax for corporate & charter pilots Its own page: corporate & charter pilots tax — mechanism, deadlines and published fees.
Airline pilots — relief you're probably missing Everything on airline pilots relief you're probably missing, at the same depth as this page.
Civil & structural engineers — relief you're probably missing Civil & structural engineers relief you're probably missing — the guide, the FAQ and the fixed fee.
IT staffing firms cross-border tax The full guide to it staffing firms cross border tax, with the fee fixed before any work starts.
Cross-border truck drivers — what you owe in each country Its own page: cross-border truck drivers what you owe in each country — mechanism, deadlines and published fees.
Twitch & live streamers — what you owe in each country Everything on twitch & live streamers what you owe in each country, at the same depth as this page.
Tax for civil & structural engineers Civil & structural engineers tax — the guide, the FAQ and the fixed fee.

Countries and corridors this work reaches

Chile tax for expats — country guide Chile tax for expats — the guide, the FAQ and the fixed fee.
Zimbabwe tax for expats — country guide The full guide to zimbabwe tax for expats, with the fee fixed before any work starts.
Canada–Australia tax corridor Its own page: Canada Australia tax — mechanism, deadlines and published fees.
Senegal tax for expats — country guide Everything on senegal tax for expats, at the same depth as this page.
France tax for expats — country guide France tax for expats — the guide, the FAQ and the fixed fee.
Peru tax for expats — country guide The full guide to Peru tax for expats, with the fee fixed before any work starts.
Philippines tax for expats — country guide Its own page: Philippines tax for expats — mechanism, deadlines and published fees.
Kenya tax for expats — country guide Everything on Kenya tax for expats, at the same depth as this page.
Canada–India tax corridor Canada India tax — the guide, the FAQ and the fixed fee.

The people on your file

Five named practitioners, each with the part of a cross-border file they carry. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.

Udit Gupta

Udit Gupta

Cross-Border Tax Expert

CA (ICAI), In-Depth Tax Trained

Reviews and signs off the practice's cross-border positions, and carries final responsibility for the treaty analysis on every file that leaves the office.

Abhinav Gupta

Abhinav Gupta

Canada Tax / International Tax

Canada Tax, International Tax, Cross-Border Tax, Transfer Pricing

Canadian returns with foreign income, non-resident filings, and the transfer-pricing documentation that runs alongside intercompany work.

Raghav Gupta

Raghav Gupta

International Tax

International Tax, Transfer Pricing Specialist

Benchmarking, method selection and the local-file and master-file sets that support a group's pricing policy under examination.

Anmol Mittal

Anmol Mittal

Canada and US tax

CPA Canada, CPA USA, CA (ICAI)

Files that have to be right on both sides of the border at once — dual filings, streamlined catch-ups, and the foreign tax credit reconciliation between them.

Vinayak Indolia

Vinayak Indolia

CFO advisory

CPA, CA. Fractional CFO and Senior Advisory Specialist

Groups that need the tax position and the finance function to agree: structure reviews, intercompany policy, and the reporting a board can act on.

Meet the whole team

What these engagements turn on

Case study 1

Holding structure reviewed while the visa application was still drafted

An applicant's immigration counsel had specified an entity to hold the qualifying investment, chosen to satisfy the programme's control and capital criteria. We reviewed that entity against the tax position before the capital moved: how the return would be taxed, what would happen on a later disposal, and what reporting would follow once residency began. One element of the design would have created a reporting obligation that served no purpose. The engagement produced a written note reconciling the immigration criteria with the tax outcome, and an amended holding arrangement agreed by both advisers before the application was filed.

Case study 2

Residency start date established before a planned share disposal

A client arriving on an investor programme intended to sell a long-held shareholding and had assumed the visa grant date was the relevant tax date. We worked through presence and ties to establish when residency was likely to begin, which was some months later than the grant. That difference put the planned disposal on a different side of the line from where the client had placed it. The work produced a documented residency analysis, a revised sequence for the disposal and the arrival, and a file of contemporaneous evidence supporting the date relied upon.

Case study 3

Two arrival dates mapped for a family moving in stages

A founder moved first to establish the business while a spouse and school-age children followed later in the year. Everyone had assumed one family start date. Analysing each person separately produced different likely start dates and different consequences for assets held in each spouse's name. The engagement produced a person-by-person residency map, a schedule of what was expected to be realised in the intervening window and by whom, and written advice on the retained family home in the previous country and how it affected the earlier arrival's position.

Case study 4

Pre-arrival asset inventory assembled while records were still reachable

An incoming investor held accounts, property and private company shares across two countries, some inherited, with acquisition records held by institutions that respond slowly to overseas requests. We built the inventory before arrival: ownership, location, title, cost and acquisition date, with supporting documents collected while the client was still on the ground. The work produced a complete asset schedule with evidence attached, identification of the holdings that would fall within reporting obligations once residency began, and a short list of items where documentation could not be obtained and an alternative basis had to be established.

Case study 5

Qualifying capital moved out of an entity chosen for the wrong reason

A start-up visa applicant had placed the qualifying capital in an entity selected years earlier for an unrelated venture, because it already existed and the funds were sitting in it. Nobody had asked what that entity did to the investment return or to a later exit. We set out the consequences of leaving the capital where it was against moving it before residency began, including the cost of the move itself. The engagement produced a written comparison, the restructuring steps taken while the client was still non-resident, and documentation of the commercial reasons for each step.

Case study 6

Departure from one country planned alongside arrival under a programme

A client leaving one country to take up an investor programme in another had treated the two events as separate matters handled by separate advisers. They interact: what is deemed to happen on departure, and what the new country does with the same assets, have to be sequenced against each other. We coordinated both sides on a single timeline. The work produced a combined departure and arrival schedule, a written position on the assets affected by both sets of rules, and the filing obligations each country expected in the year of the move.

Case study 7

Fifteen Per Cent Held Back From a Fee for Services in Canada

A payer must withhold from fees paid to a non-resident for services rendered in Canada, whether or not any tax is ultimately owed. A waiver applied for before the work is invoiced avoids the withholding; after it, the money comes back through a return.

Read how this one runs
Case study 8

An Estate Using Its Graduated Rates in Time

The favourable rate treatment an estate can access is time-limited and conditional, and it is lost by administration rather than by decision. The file identifies the window and the filings that keep it open.

Read how this one runs

All case studies — every published engagement in one place.

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.

U.S. & Cross-Border Tax Returns

Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.

Expat & Emigration Tax

The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.

Non-Resident Canadian Tax

Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

Cross-Border Estates & Trusts

Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

Canadian Tax with a Foreign Element

Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

UAE Tax for Expats & Their Home Country

A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies

Global E-commerce & Marketplaces

  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces

Technology & SaaS

  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS

Cross-Border Real Estate

Foreign property income and sales are taxed in both countries by default; Section 216, FIRPTA and treaty credits are the standing toolkit.

Property is taxed where it sits, which is the one rule no treaty overrides. What the treaty does decide is the credit, the rate on the rent and what happens on the sale — and the clearance certificate on a disposition is applied for before closing, not after the buyer has already held the money back.

  • Section 216 rental returns
  • FIRPTA withholding recovery
  • Section 116 clearance
  • Treaty credit optimization
Explore Real Estate

Importers, Exporters & Manufacturers

  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing

Athletes, Artists & Entertainers

  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers

Remote Workers & Digital Nomads

  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers

Investment Funds & Holding Companies

  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos

Investor & start-up visa tax — questions we are asked

Investor & start-up visa tax — can I handle this 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: where the investment sits, whether it is held personally or through an entity, and when residency begins all determine the tax outcome.

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.

When does my tax residency start if I arrive on an investor visa?

Not on the day the visa is granted, in most cases. Residency starts from facts about presence and ties, and those facts are usually established by arrival and settlement rather than by the immigration decision itself. The gap between the two dates matters, because anything realised before residency begins is generally outside the new country's reach and anything realised after it may not be. Fix the likely start date early, in writing, and then schedule the transactions around it. Clients who assume the visa date is the tax date frequently discover afterwards that a sale they timed carefully fell on the wrong side of the line.

Should I hold my visa investment personally or through a company?

That choice is usually made by immigration counsel, for immigration reasons, and then inherited by the tax position without anyone testing it. Holding personally and holding through an entity produce different outcomes on the income the investment generates, on any later disposal, and on what has to be reported once you are resident. Neither is automatically better. What causes damage is deciding it against the visa programme's criteria alone and discovering the tax consequence after the capital has been committed, when changing the holder is itself a taxable event. Raise the question while the application is being drafted, not after approval.

My family arrives six months after me — does that change my tax?

It can change both of your positions, and they may not start at the same time. Residency is determined person by person, so a spouse and children who arrive later may begin their own residency on a different date. Family ties in either country also feed into how the residence question is answered for the person who arrived first, particularly where the home in the previous country is retained for them. Map each person's expected start date separately, then look at what is being realised in the window between them. A single family date applied to everyone is one of the more common planning errors here.

Do I have to report assets I already own before the visa is granted?

Reporting obligations generally attach to residence rather than to when the asset was acquired, so assets you have held for years can come into scope the moment residency begins. That includes holdings that produce no income and are not being sold. The practical work is building the inventory before arrival: what is owned, where, in whose name, and what documentation exists for cost and acquisition date. Assembling that later, from institutions in another country, takes far longer and sometimes cannot be completed at all. The inventory is also what the pre-arrival planning is done against, so it is the first task rather than a later one.

Should I sell my appreciated shares before or after I move?

It depends on what each country does with the gain and on where your residency start date falls, and that is exactly why the date should be established first. A disposal before residency begins is generally measured against the old country's rules; one after it may be within the new country's reach as well, with relief for the overlap depending on the treaty position. There is no general answer that holds for every asset and every pair of countries. What can be said generally is that the decision is cheap to make in the months before arrival and expensive to revisit afterwards.

Does the structure my immigration lawyer set up work for tax too?

Sometimes, but it was not designed to. Investor and start-up programmes are built around capital and business plans, and the holding structure is generally chosen to satisfy the programme's criteria on qualifying investment and control. Those criteria have nothing to do with how the return is taxed, how a later exit is treated, or what has to be reported once you are resident. The two designs can be reconciled, and usually are, but only if someone looks at them together before the capital is placed. Ask for the immigration structure to be reviewed against the tax position while both are still drafts.

Branch or subsidiary — which should we use to expand?

A branch keeps one taxpayer: results consolidate at home, losses are usable sooner, and the exposure is that the branch is a permanent establishment whose profit the host country taxes, sometimes with a branch tax on repatriation. A subsidiary is a separate taxpayer with limited liability and local rates, at the cost of withholding on dividends home and transfer pricing on everything between them. The deciding facts are usually expected losses, liability and exit plans. See branch against subsidiary.

Is double taxation illegal?

It is legal. Two countries can each have a valid claim on the same income — one because the income arose there, the other because you live there — and nothing prohibits both from exercising it. What exists instead is relief: tax treaties allocate the claim, and domestic law gives a credit for foreign tax paid. The relief is not automatic, though. It is claimed on a return, and unclaimed relief is simply lost. See how double taxation is relieved.

A named reviewer on every filing

A fixed fee for investor & start-up visa tax

We scope it on a call, quote it in writing, and you see the result before anything is filed.

  • 24-hour helpline, +1 (416) 619-0068
  • A named reviewer signs off every filing
  • 18,000+ clients served

Our practitioners are alumni of leading accounting and tax institutions

Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

Request a Quote +1 (416) 619-0068