Canada - English

Complex Planning 

Today’s organizations can benefit from comprehensive and practical solutions to complex problems.  

At KPMG, we strive to understand the long-term impact of tax decisions and bring clients some of the most progressive tax planning ideas. Below we profile some of our leading tax professionals and the types of complex tax planning situations they can help you manage.

 

Mergers, Acquisitions and Divestitures
  • Structuring complex corporate reorganizations, including amalgamations, butterflies, spin-offs, and wind-ups
  • Achieving tax cost base adjustments and making tax-efficient use of losses
  • Conducting thorough, value-based due diligence reviews
  • Post-transaction planning for the integration of companies
  • Preparing advance tax ruling requests and negotiating with tax authorities regarding the transaction's structure and taxation.

 


Rick McLean
Toronto

Tax Accounting and Reporting

  • Providing specific tax technical support in accounting for income taxes and preparing income tax provisions for public and private enterprises under Canadian and US GAAP, International Financial Reporting Standards (IFRS), and Accounting Standards for Private Enterprises (ASPE) 
  • Guidance on the application of accounting standards and financial statement impact of complex transactions, such as complex reorganizations, investments in foreign affiliates, and international financing arrangements
  • Company-specific employee training on tax accounting standards and best practices, including converting to and implementing IFRS and ASPE
  • Providing advice and recommendations to the CICA on tax-related exposure drafts of revised standards
  • Representing the tax community on the Canada Revenue Agency's (CRA) Advisory Committee on Tax Administration to develop tax policy related to the implementation of IFRS in Canada.

 


Pam Zabarylo
Toronto

Cross-Border Structures

  • Developing and maintaining cross-border financing arrangements to help optimize international tax benefits for Canadian-based and foreign multinational enterprises
  • Planning cross-border investments in light of Canada's current and proposed foreign affiliate rules and developing systems to manage your related reporting obligations
  • Disposition and repatriation planning for international investments
  • Establishing, reviewing, and reorganizing global structures in light of changing legislation, and new tax treaties, protocols, and information exchange agreements
  • Structuring intellectual property ownership to help optimize tax treatment across jurisdictions

 


Marc Desrosiers
Montréal

US Tax Planning

  • Structuring investments, acquisitions, and business expansion into the United States
  • Conducting strategic and risk-based US tax due diligence
  • Reorganizing US corporate and other business structures
  • Structuring tax-effective cross-border financing
  • Disposition and repatriation planning for US investments
  • Utilizing hybrid entities and financial instruments
  • Planning that integrates the Canadian, US, and Canada-US tax treaty rules.

 


Tony P. Swiderski
Vancouver

GAAR, Statutory Interpretation, and Legal Opinions

  • Preparing opinions that have the benefit of solicitor-client privilege through our KPMG-affiliated tax legal firm Moskowitz & Meredith LLP (M+M)
  • Analyzing the applicability of GAAR and specific anti-avoidance rules to proposed transactions
  • Resolving complex tax provisions in accordance with evolving approaches to statutory interpretation.

Mark Meredith
M+M – Vancouver

Denis Lacroix
M+M – Montréal