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AREAS OF PRACTICE
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| Over the years,
Michael Atlas has assisted in connection
with thousands of different tax issues. Listed below is a sample of the most common types. |
| Corporate & Business Tax
Issues
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- Mergers and acquisitions
- Corporate reorganizations
- Incorporation of unincorporated businesses
- Minimizing tax on the sale of shares of corporations
by using the "capital gains exemption"
- Minimizing tax on the sale of shares of corporations
by using "safe income strips"
- Utilizing corporate tax losses
- Partnership formation, reorganization, and dissolution
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Optimizing dividend/salary policy
- Maximizing the use of the "small business deduction"
- Rolling over shares to holding companies
- Creditor proofing reorganizations
- Structuring shareholder buy/sell agreements
- Advising re foreign corporations operating in Canada
- Advising re Canadian corporations operating outside of
Canada
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| Estate Planning |
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- Estate "freezing" of private corporations so
that tax on death is minimized
- Reviewing and advising on wills in order to avoid tax
pitfalls and minimize taxes payable on death
- Advising in connection with the formation and terms of
family trusts created during the lifetimes of individuals
- Planning aimed at minimizing exposure to probate fees
on death
- Planning aimed at minimizing exposure to U.S. estate
taxes
- Post-mortem planning aimed at avoiding double taxation
in connection with shares of private corporations owned
on death
- Planning issues re corporate-owned life insurance
- Structuring shareholder buy/sell agreements
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| Real Estate
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Ownership structures re acquisition
of real estate
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Minimizing or deferring tax on real
estate gains
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Maximizing utilization of tax losses
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Structuring joint ventures or syndications
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Capital gain versus income determinations
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Principal residence issues
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Non-resident investment in Canadian
real estate
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Canadian investment in foreign real
estate
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Creditor proofing real estate holdings
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| In-bound International
Tax
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- Tax planning for immigration to Canada
- Tax planning for returning Canadian expatriates
- Investment in Canadian businesses and real estate by
non-residents
- Non-residents carrying on business in Canada
- Canadian subsidiaries of foreign corporations
- Tax treaty issues
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| Out-bound International Tax |
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- Tax planning for emigration from Canada
- Post-emigration expatriate issues
- Investment by Canadians in foreign businesses and corporations
- Offshore tax planning and the use of tax havens
- Investments by Canadians in foreign real estate
- Tax issues re offshore trusts
Michael Atlas does not, except in very rare circumstances, provide tax
compliance services, such as preparing tax returns. |
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