Canadian Tax Consultant Chartered Accountant International Tax Consultant Canadian Tax Professional Canadian Tax Accountant Michael Atlas - Canadian Tax Consultant US Tax Consultant
Michael Atlas - Canadian Tax Consultant
ABOUT MICHAEL ATLAS - A comprehensive summary of Michael Atlas' professional background and experience, as well as a listing of his extensive writings in the tax field AREAS OF PRACTICE - A description of the areas of tax practice in which he has extensive interest and expertise PROFESSIONAL FEES - Information on Michael Atlas' general approach to fees CANADIAN TAX GUIDE FOR NON-RESIDENTS - A useful summary of the application of Canadian tax rules for non-residents earning income from Canadian sources-includes analysis by type of income and application of major tax treaties CONTACTING MICHAEL ATLAS - Everything you need to know about contacting Michael Atlas
ABOUT MICHAEL ATLAS - A comprehensive summary of Michael Atlas' professional background and experience, as well as a listing of his extensive writings in the tax field
AREAS OF PRACTICE - A description of the areas of tax practice in which he has extensive interest and expertise
PROFESSIONAL FEES - Information on Michael Atlas' general approach to fees
CANADIAN TAX GUIDE FOR NON-RESIDENTS - A useful summary of the application of Canadian tax rules for non-residents earning income from Canadian sources-includes analysis by type of income and application of major tax treaties
CONTACTING MICHAEL ATLAS - Everything you need to know about contacting Michael Atlas

 

 

(Michael Atlas with family-Fathers' Day 2007)

 

 

ABOUT 

MICHAEL ATLAS

 


EDUCATION & PROFESSIONAL DESIGNATIONS

B.A.-University of Texas at Austin, June 1967

C.A.-Institute of Chartered Accountants of Ontario, 1972

C.P.A.-State of Illinois, 2000

T.E.P.-Society of Trust and Estate Practitioners, 1999  


MEMBERSHIPS

 


 

PROFESSIONAL EXPERIENCE

1991-Present-Independent tax consultant on wide variety of Canadian tax matters.

1972-1991-In charge of tax group at Soberman Isenbaum & Colomby, Chartered Accountants, Toronto (admitted to partnership 1974). This firm (now called Soberman LLP) is one of the 15  largest accounting firms in Canada.


BOOKS, PAPERS, ARTICLES AND SPEAKING ENGAGEMENTS

Books Authored By Michael Atlas

Canadian Taxation of Non-Residents (CCH Canadian Ltd.)- Soft covered book, originally published in 1995, second edition  published in  May of 2002

Canadian Taxation of Real Estate (CCH Canadian Ltd.)-Soft covered book, originally published in 1987, subsequent editions published in 1989 and 1992. A 4th edition, co-authored by Ian V. MacInnis, was published in July 2004. 

Taxation of Real Estate in Canada (Carswell/DeBoo)-Hard covered book in looseleaf format, originally published in 1989. Subsequent updates authored by Michael Atlas until 1995.

Advanced Real Estate Taxation course adopted in 1991 by Canadian Real Estate Association as part of its "CCIM" designation program.

 

Papers, Presentation and Lectures Given By Michael Atlas

Presentations entitled "Tax Issues For Non-Resident Investors in Canadian Real Estate", as part of "Creative Tax Planning For Real Estate Transactions", Federated Press, September 21, 2006, June 14, 2007, and December 28, 2007

Presentation entitled "Canadian Tax Implications of Selected Hybrid Entities", as part of 8th Canadian National Conference of Society of Trust and Estate Practitioners, June 12, 2006.

Presentation entitled "Computing Income From FIEs", Society of Trust and Estate Practitioners September 12, 2005

Participant in "Estate Freeze From Hell" presentation, as part of 6th Canadian National Conference of Society of Trust and Estate Practitioners, June 7, 2004.

Presentation entitled "Canadian Tax Considerations For Businesses Expanding To The U.S.", Lorman Seminar on Cross-Border Tax Issues, November 17, 2000, and November 16, 2001

Presentation entitled "FIEs-Anomalies, Problems, And Pitfalls", Society of Trust and Estate Practitioners July 10, 2000

Presentation entitled "Closing The Tax-Free Offshore Pipeline", Society of Trust and Estate Practitioners National Conference, October 20, 1999

Presentation entitled "Taxation Of Offshore Trusts: Impact of Proposed Changes-December 23, 1998 and February 16, 1999", Society of Trust and Estate Practitioners, March 1, 1999

Dinner speaker for York District and North York Chartered Accountants Association in 1991, 1992, 1994, 1995 and 1998

Guest speaker at 1992 Bar Admission Course of Law Society of Upper Canada on taxation of deceased taxpayers and trusts.

"Investment In U.S. Rental Real Estate-Canadian Tax Implications"1998 Ontario Conference, Canadian Tax Foundation

"Estate Freezing and Other Issues" as part of case study presented at 1991 Ontario Tax Conference of Canadian Tax Foundation.

"Effective Utilization of Tax Losses" paper presented for United Jewish Welfare Fund in June 1991.

"Loss Utilization Planning", as part of Real Estate Taxation conference presented by The Canadian Institute, February 1991.

"GST and Residential Real Estate", 1990 Annual Conference, Canadian Tax Foundation

"GST and Real Estate", 1990 Ontario Tax Conference, Canadian Tax Foundation

"Income Tax Issues in Real Estate Leasing", 1989 Corporate Management Tax Conference, Canadian Tax Foundation.

Presentation entitled "Tax Planning of Real Estate Related Transactions under Tax Reform", Continuing Legal Education, Canadian Bar Association-Ontario-1988

"Planning for the Capital Gains Exemption", at Small Business Financing and Tax Conference, CCH Canadian Limited, 1986

"Owner/Manager Remuneration", Small Business Financing and Tax Conference, CCH Canadian Limited, 1985

Speaker at various conferences sponsored by Canadian Real Estate Association, Mississauga Real Estate Board and Society of Industrial and Office Realtors.

Lecturer in taxation at many professional development courses sponsored by Institute of Chartered Accountants of Ontario, 1982-1984.

 

Articles Written By Michael Atlas

Tax Topics (published by CCH Canadian Limited)

"Beware of Pitfalls in November 9, 2006 Technical Amendments When Crystallizing 'Safe Income' "-Issue 1820,  January 25, 2007

"Post-Mortem Tax Planning In Connection With Corporate-Owned Life Insurance"-Issue 1690,  July 29, 2004

"Post-Mortem Tax Planning In Connection With Shares of Canadian Private Corporations-More On The 'Pipeline'"-Issue 1635, July 10, 2003

"New FAPI 'Fresh Start' Rules Released-Wording Re Capital Gains Less Than Clear; Change Of Business Pitfall Added"-Issue 1614 February 13, 2003

"Post-Mortem Tax Planning Using Subsection 164(6) In Connection With Shares Of Canadian Private Corporations"-Issue 1582 July 4, 2002 

"CCRA Softens Stance On Late-Filed 216(1) Returns"-Issue 1560 January 31, 2002

"FIE Proposals Will Make FAPI Seem Like Heaven!"-Issue 1480, July 20, 2000

"Watch Out For Those U.S. Pubco Spinoffs!"-Issue 1472, May 25, 2000

"Federal Budget Targets Offshore Trusts"-Issue 1411, March 25, 1999

"The December 23, 1998 Proposals-Impact On Offshore Trusts"-Issue 1404, February 4, 1999

"What's A CCPC?"-Issue 1378, August 6, 1998

"Sherway Centre Decision May Have Far-Reaching International Tax Implications"-Issue 1374, July 9, 1998

"Federal Budget Proposals May Allow Non-Residents To Repatriate Cost Of Shares In Canadian Corporations Tax-Free"-Issue 1365, May 7, 1998

"Remember June 30 Deadline For Most Subsection 216(1) Returns"-Issue 1318-19, June 19, 1997

"Transitional Issues Still Cloud Application of New FAPI Rules"-Issue 1313, May 8, 1997

"Don't Get Burned By Revised 69(11) When Utilizing Corporate Losses Within The Family!"-Issue 1302, February 21, 1997

"Tax Planning For Trusts With Non-Resident Beneficiaries In Light of October 2, 1996 Proposals-Part II"-Issue 1287, November 7, 1996

"Tax Planning For Trusts With Non-Resident Beneficiaries In Light of October 2, 1996 Proposals-Part I"-Issue 1285, October 24, 1996

"Shift To 5% Treaty Rate On Dividends From Canadian Subsidiaries May Facilitate Global Tax Planning"-Issue 1258, April 18, 1996

"The New Spousal Rollover In The Canada-U.S. Tax Treaty-Part II"-Issue 1253, March 14, 1996

"The New Spousal Rollover In The Canada-U.S. Tax Treaty-Part I"-Issue 1252, March 7, 1996

"Tax Planning For Foreign Inheritances"-Issue 1247, February 1, 1996

"Canada Widens Power To Tax Non-Residents' Capital Gains-Very Quietly!"-Issue 1212, June 1, 1995

Offshore Finance Canada

"Avoiding Canadian Taxation of Business Profits Treated as FAPI", Volume 3, No. 6, November/December 1998

"Offshore Planning In The Family Business", Volume 3, No. 2, March/April 1998

International Tax (published by CCH Canadian Limited)

"Route Taken In Going Public Can Affect Non-Residents' Canadian Tax Position"-No. 1, December 2000

Other Publications

"A Canadian Perspective On U.S. LLCs" LLC Advisor, CCH Incorporated, Issue Number 18, February 27, 1997

Many articles on various aspects of real estate taxation that have appeared in Globe & Mail, Resource, Real Estate Journal, CCIM Canada Canadian Appraiser, and Toronto Office Leasing Guide.

Quoted on many occasions in articles that have appeared in National Post and Toronto Star.