Hello
Canadian corp has two shareholder 50% each , one being Canadian resident and the other one is USA corporation. This is first tax year for Canadian corp do we need to attach S91 & S97 ?
Firstly, you are jumping the gun here. You need to determine the residency status of the corporation by performing the mind & management test (if the directors of the company are Canadian, and reside in Canada, then it’s a CCPC, and vice-versa).
If the answer is no, you are dealing with a completely different beast altogether. You may want to consider a reorganization for a 51% Canadian ownership, and dual share class structure.
In all honesty, if you have to ask the question of residency, you should really have this file assigned to somebody who specializes in cross-board taxation. Start with my initial query and let’s go from there… this is a very broad topic area of discussion.
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It is not only a broad topic of discussion but a very important topic; you probably can not afford to not bring in a cross border tax specialist.
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The corporation will also be taxable in the USA because of the US shareholder I agree, stay away - too many conditions and exemptions
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Thanks. I will pass it on to cross boarder tax expert. Really appreciate all your support.
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