Competitively priced Real estate holding structures

Holding foreign real estate personally, through a company, or through a trust changes the tax on rent, the tax on sale, the estate exposure and the reporting — usually in different directions. Competitively priced real estate holding structures with a fixed fee agreed in writing before any work starts. Call the 24-hour helpline on +1 (416) 619-0068, or request a written 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
  • 18,000+ clients served
  • Google rating 5.0 out of 5
  • Offices in India, the USA, Canada and the UAE
The short answer

Holding foreign real estate personally, through a company, or through a trust changes the tax on rent, the tax on sale, the estate exposure and the reporting — usually in different directions. Local rules often tax property income and gains at source regardless of the holder, while the holder's home country taxes again with credit.

Whether this is your situation

  • Income is being reported in one country and not the other
  • A purchaser is holding back proceeds pending a certificate
  • You hold property or securities in another country
  • Foreign withholding does not appear to reduce your home tax
  • You are selling a foreign asset

Any two of those together and real estate holding structures is almost certainly your situation. If nothing on the list applies, the helpline call still costs nothing and we will redirect you.

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

Transparent, fixed pricing for real estate holding structures

What sets the fee on a real estate holding structure is the number of properties and the number of countries with a claim on them, since the personal, company and trust options have to be modelled in each. Adding succession and estate exposure to the comparison is the second variable. Fixed fee agreed in writing first.

PE / structure opinion — fixed-fee price

From $999

fixed, quoted before work starts

A written opinion on whether the activity creates a taxable presence, what would be attributable to it if it did, and what could be changed to alter the answer.
See the full fee page

Section 216 rental return — fixed-fee price

From $349

fixed, quoted before work starts

The elective Canadian rental return on net income, with the deductions the gross withholding ignored, plus the pre-year undertaking where the timing still allows it.
See the full fee page

Corporate cross-border filing

From $999

fixed, quoted before work starts

The corporate return and its cross-border schedules as one engagement, so the group files a consistent position everywhere.
See the fee schedule

Non-resident & departure filings

From $349

fixed, quoted before work starts

Non-resident filings and the two part-year returns a move produces, sequenced so neither country taxes the same income twice.
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

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

Benchmarking and documentation for related-party dealings, prepared to the standard the reviewing authority applies.
See the fee schedule

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

Payroll & mobility setup

From $999

fixed, quoted before work starts

The employer side of mobility — where to register, what to withhold, and what to report once someone works across a border.
See the fee schedule

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

What the rule does, step by step

Holding foreign real estate personally, through a company, or through a trust changes the tax on rent, the tax on sale, the estate exposure and the reporting — usually in different directions.

Local rules often tax property income and gains at source regardless of the holder, while the holder's home country taxes again with credit. Estate and succession consequences frequently decide the structure more than the annual rate does.

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 repatriating money out of India and pillar two readiness assessment.

What we actually file

  • Withholding reductions, elections and clearance applications
  • Foreign property reporting on the correct measure
  • Credit computations by category and by country
  • Depreciation and recapture schedules where a property was rented
  • Cost-base reconstruction across a change of residence

What this looks like with numbers

The same point, with figures rather than adjectives.

Gross withholding against a net-basis return

A non-resident receives C$28,000 in the year. Assume withholding at 22% on the gross amount, and assume deductible costs of C$19,320 against it.

Gross withholding against a net-basis return
ItemAmount
Gross amount receivedC$28,000
Withheld at source (assumed 22% of gross)C$6,160
Deductible costsC$19,320
Net amount actually earnedC$8,680
Tax on the net amount (assumed graduated result)C$1,823
Difference recoverable by filingC$4,337

Filing on a net basis recovers C$4,337 of the C$6,160 withheld. That difference is the entire reason the elective return exists, and it is lost by not filing. Change any one of those inputs and the answer moves, which is why we run it on your own figures rather than on an illustration.

Example figures throughout, selected to make the rule visible, with rates and thresholds assumed for the demonstration. Your actual filing uses figures confirmed with the issuing authority for your tax year.

From first call to filed

  1. 1A call to the 24-hour helpline to find out whether this is a filing or a project
  2. 2A fixed fee for a written scope — re-quoted if the scope changes, never invoiced silently
  3. 3Preparation against the evidence, with the positions documented as we go
  4. 4Your approval, then the filing — in that order

What it costs

You get a number before you commit, not an estimate that drifts. The scope is written down, the fee is fixed against it, and if the scope changes we re-quote rather than invoice the difference. Comparable engagements and their fixed fees are set out on the pricing pages.

  • Nothing is filed until you have read it.
  • Consultations scheduled to your working day rather than ours.
  • A named reviewer signs off every statutory filing.

What to do next

Ask before the move rather than after it, because most of the useful options expire on the date. Bring the last two years of returns from each country involved, the slips or certificates for the income in question, and the dates — arrival, departure, or the transaction date. That is enough for us to tell you what has to be filed and what it will cost.

Reviewed for accuracy 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

People reach this page searching for business tax advisory. It is covered here as it applies to real estate holding structures — who it applies to, what has to be filed, and what it costs, at a fixed fee agreed before the work starts.

Holding foreign real estate personally, through a company, or through a trust changes the tax on rent, the tax on sale, the estate exposure and the reporting — usually in different directions.

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.

How real estate holding structures is handled here

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

The vocabulary this page leans on

Construction PE
A permanent establishment created by a building site or installation project lasting beyond the treaty's duration threshold.
FIRPTA
The US regime taxing a foreign person's disposition of US real property interests, enforced by withholding from the sale proceeds by the buyer.
FC-GPR
The Indian reporting of shares issued to a foreign investor, due within days of the transaction and compounding if late.
Staking reward
Consideration received for participating in a network, generally an income event valued at receipt and becoming the cost base for a later disposal.
real estate holding structures: How we read this one

Local rules often tax property income and gains at source regardless of the holder, while the holder's home country taxes again with credit.

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.

Real estate holding structures — what the published fees look like

These fees separate advice given before a property is bought from restructuring something already held, where a transfer between holders can itself be a taxable event and has to be costed on both sides of the border. The reporting each option carries afterwards is quoted with it.

Section 216 rental return

$349fixed, before work starts

Covers: The elective Canadian rental return on net income, with the deductions the gross withholding ignored, plus the pre-year undertaking where the timing still allows it.

What makes it bigger: The number of properties and whether the records separate repairs from improvements. One property with an agent's statement is quick; four properties with mixed receipts is not.

See this fee page

PE / structure opinion

$999fixed, before work starts

Covers: A written opinion on whether the activity creates a taxable presence, what would be attributable to it if it did, and what could be changed to alter the answer.

What makes it bigger: How many people and places are involved. One employee working from home is one analysis; a sales team, a warehouse and a contractor with signing authority is several.

See this fee page

Why choose Legal Quotient for real estate holding structures

The quote comes from your documents

Nothing is priced from a phone call. We read what you have first, then the fee is set — so the scope and the number are agreed on the same evidence.

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.

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.

18,000+ clients served

Individuals, expats and corporations across India, the USA, Canada and the UAE have filed with us — 15+ years of cross-border work.

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

How the engagement runs, phase by phase

Step 1

First conversation

We establish what happened and when, because every position here is anchored to a date

Step 2

Written quote

A written scope and a fixed price, so you know the cost before committing

Step 3

Preparation and sign-off

The filings are prepared, cross-checked against each other, and reviewed by name

Step 4

Submission

You see the result, approve it, 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.

Services these clients use most

Form T2062 — section 116 clearance certificate Everything on T2062 section 116 clearance certificate, at the same depth as this page.
Terminal return & clearance certificate Terminal return & clearance certificate — the guide, the FAQ and the fixed fee.
Indian reassessment notices (s.148) The full guide to Indian reassessment notice 148, with the fee fixed before any work starts.
Study permit holders Its own page: study permit holders — mechanism, deadlines and published fees.
Repatriating sale proceeds out of India Everything on repatriating sale proceeds out of India, at the same depth as this page.
Canadian subsidiary — cross-border compliance red flags Cross-border tax compliance red flags Canadian subsidiary — the guide, the FAQ and the fixed fee.
Canada–India DTAA explained The full guide to Canada India DTAA explained, with the fee fixed before any work starts.
DTAA relief — India and Canada Its own page: DTAA relief — India and Canada — mechanism, deadlines and published fees.
Staking & yield income Everything on staking & yield income, at the same depth as this page.

Clients who arrive with this exact page

Nurses working abroad — what you owe in each country Everything on nurses working abroad what you owe in each country, at the same depth as this page.
Tax for gig-economy drivers & couriers Gig-economy drivers & couriers tax — the guide, the FAQ and the fixed fee.
Tax for team-sport athletes The full guide to team-sport athletes tax, with the fee fixed before any work starts.
Tax for mechanical & electrical engineers Its own page: mechanical & electrical engineers tax — mechanism, deadlines and published fees.
Software developers — your filing calendar Everything on software developers your filing calendar, at the same depth as this page.
Touring musicians — relief you're probably missing Touring musicians relief you're probably missing — the guide, the FAQ and the fixed fee.
Tax for day traders The full guide to day traders tax, with the fee fixed before any work starts.
Management consultants — what you owe in each country Its own page: management consultants what you owe in each country — mechanism, deadlines and published fees.
Education & ed-tech cross-border tax Everything on education & ed-tech cross border tax, at the same depth as this page.

The corridors we work every week

Morocco tax for expats — country guide Everything on morocco tax for expats, at the same depth as this page.
India–Singapore tax corridor India Singapore tax — the guide, the FAQ and the fixed fee.
Brazil tax for expats — country guide The full guide to Brazil tax for expats, with the fee fixed before any work starts.
Iceland tax for expats — country guide Its own page: Iceland tax for expats — mechanism, deadlines and published fees.
Oman tax for expats — country guide Everything on Oman tax for expats, at the same depth as this page.
Norway tax for expats — country guide Norway tax for expats — the guide, the FAQ and the fixed fee.
India–United Kingdom tax corridor The full guide to India United Kingdom tax, with the fee fixed before any work starts.
Qatar tax for expats — country guide Its own page: Qatar tax for expats — mechanism, deadlines and published fees.
South Africa tax for expats — country guide Everything on South Africa tax for expats, at the same depth as this page.

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

Cross-border tax case studies

Case study 1

Comparing three holding options before a purchase completed

Buyers were about to sign for an apartment abroad and had been told, informally, to use a company. The engagement compared three routes: personal ownership, a local company, and a company in a third country. For each we set out the treatment of rental income at source, the treatment of the eventual gain, the position on death, and the reporting that would follow at home. The comparison was written as a single table with the reasoning beneath it. The buyers chose personal ownership for reasons that had nothing to do with the annual rate, and the file records why.

Case study 2

Unwinding a company that held a single rental flat

A company had been set up years earlier to hold one apartment, on advice nobody could now locate. It generated a local corporate filing, an accounts requirement, and a second layer between the owner and a credit for the foreign tax. The work was to establish what unwinding would cost in both countries, what the reporting obligations were while it remained, and whether the succession reason for its existence still held. The structure was wound up across a full cycle of filings, and the property moved into personal ownership with the corporate history documented for the authority on each side.

Case study 3

Establishing the estate exposure on a second overseas property

An owner with property in two countries had planned the succession for one and assumed the other followed the same rules. It did not. We set out how each country treats land on death, where the estate would need a local process, and which of the two applied rules that a will could not override. The engagement produced a written statement of the exposure in each jurisdiction and a note for the executors describing what would have to be done, in which order, and in which country first. One holding was restructured. The other was left alone, deliberately, with the reasoning recorded.

Case study 4

Releasing withheld proceeds after a non-resident property sale

A sale had completed and a substantial part of the price was sitting with the purchaser's agent pending a certificate from the tax authority. The seller had no local adviser and no idea what had triggered it. We assembled the acquisition documents, the improvement costs and the sale contract, computed the gain on the local basis rather than on the sale price, and filed what the certificate application required. The withheld funds were released against the certificate, and the same gain was then reported at home with the foreign tax claimed as a credit rather than forgotten.

Case study 5

Bringing a rental property into both countries' returns

Rent had been declared where the property sits and nowhere else, for several years, on the assumption that paying tax at source was the end of it. We recomputed the income on the home country's basis, which treated the expenses and the depreciation differently, and prepared the outstanding returns with a credit claim for the tax already paid abroad. The engagement produced a filed set of years on both sides that describe the same property consistently, and a working schedule the client can follow each year without needing the analysis done again.

Case study 6

Identifying the real holder of an inherited family property

A client had inherited a share in property held under a family arrangement that was clear to the family and to nobody else. Before any tax question could be answered, the engagement had to establish who the law of the country where the land sits treats as the owner, and how that person is characterised at home. We worked from the title documents, the succession papers and the local formalities. The result was a written determination of the holder for tax purposes on each side, which then decided who reports the rent, who reports a gain, and where.

Case study 7

Two Wills, Two Jurisdictions, One Estate

A will drawn for one country can revoke another or fail to reach assets held abroad. The review checks how each instrument interacts with the other and where probate will actually be required.

Read how this one runs
Case study 8

One Employee in a State Nobody Had Registered In

A single person working from home can create payroll registration, withholding and sometimes an income tax filing for the company in that state. The review measures activity against each state's own threshold.

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

Professional Services Firms

Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.

A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.

  • Reg 105 / 102 waivers
  • Permanent establishment risk
  • Partner mobility planning
  • Cross-border withholding recovery
Explore Professional Services

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

Real estate holding structures — questions we are asked

Real estate holding structures — 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: local rules often tax property income and gains at source regardless of the holder, while the holder's home country taxes again with credit.

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.

Should I buy property abroad personally or through a company?

There is no answer that holds across countries, because the three consequences that matter pull in different directions. A company may reduce the rate on rental income and may not. It often changes the treatment of the eventual gain. And it usually changes what happens on death, sometimes decisively. Meanwhile your home country taxes the income again and gives credit, and credit is easier to obtain for tax you paid than for tax a company paid. The order to decide in is this: what the local system does to income and gains regardless of the holder, then what your own system does with the result, then what happens on succession.

Will I be taxed twice on rent from a property overseas?

Usually the income is taxed where the property sits, and taxed again where you live, with a credit for the first against the second. So the combined cost tends towards the higher of the two rates rather than the sum, provided the credit is genuinely claimable. It is the provisos that cause the trouble. Credit generally requires that the tax was properly due, that it was paid by the same person who is claiming it, and that the income is measured the same way in both places. Different depreciation or expense rules on each side can leave part of the foreign tax stranded.

What happens to my foreign property when I die?

Often more than owners expect, and it is frequently the deciding factor in how the property should be held. Many countries assert estate, inheritance or succession tax over land inside their borders whoever owns it and wherever they live, and some apply forced heirship rules that override a will. The practical consequences are a local probate or succession process, a charge in a currency and a system your executors do not know, and an asset that cannot be sold until both are resolved. Holding the property through an entity can change which of those applies. The question belongs at the purchase, not at the estate.

Why is the buyer holding back part of my sale proceeds?

Because the local system is protecting itself against a seller who leaves. Where a non-resident sells land, many countries require the purchaser to withhold a portion of the price and remit it, releasing it only when the tax authority issues a certificate confirming the seller's position. The important feature is that withholding is applied to the sale price rather than to the gain, so it routinely exceeds the tax actually due. The money comes back, but through a filing and a certificate rather than automatically. Start that process before completion where you can. Afterwards it becomes a refund claim with its own timetable.

Does a trust stop foreign inheritance tax on my property?

Sometimes, and sometimes it creates a second problem. A trust can change who is treated as owning the land for succession purposes, which is the point of using one. But it also introduces its own taxation of income and gains, its own reporting in your home country, and a question about whether the local system recognises the arrangement at all. Several countries that tax land on death do not recognise trusts, so the structure adds cost without achieving the objective. The test is whether the law of the country where the land sits gives the trust the effect you are paying for.

I only declare the rent in one country, is that wrong?

Almost certainly, and it is among the most common things we are asked to correct. Reporting where the property sits and not at home is the usual version, on an assumption that the foreign tax settles the matter. It does not: the home country generally taxes worldwide income and relieves double taxation by credit, which has to be claimed on a return that includes the income. The reverse happens too, where rent is declared at home while the source country is never told. Correcting it is ordinary work, and the position is better dealt with by you than raised by an authority comparing information it already receives.

Is a gift from abroad taxable in Canada?

Not to the person receiving it — Canada does not tax gifts in the recipient's hands, whatever the amount. The tax questions sit elsewhere. A gift of property rather than cash is a disposition for the giver, at market value. Attribution rules can send the income the gift later earns back to the giver where the recipient is a spouse or a minor. And a gift large enough to be noticed should be documented, because "it was a gift" is a claim that gets tested. See a Canadian receiving a foreign gift.

Does GILTI apply to individuals?

Yes, and it lands harder on them. An individual US shareholder of a controlled foreign corporation has the same inclusion a corporate shareholder does, but without an election gets neither the corporate-level deduction nor credit for the foreign corporate tax already paid — so foreign profit can be taxed at individual rates with no relief for tax the company paid abroad. An election to be taxed as though through a domestic corporation is usually the first thing to model. See Form 5471 and CFCs.

Meet us in person at any of our offices

Real estate holding structures, quoted before we start

One short call, one fixed quote in writing, and your approval before anything is filed.

  • 24-hour helpline, +1 (416) 619-0068
  • Re-quoted, never silently invoiced
  • Fixed fees agreed before work starts

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