The proposed Global Minimum Tax Act (“GMT Act”) introduces a new form of taxation applicable to Canadian taxpayers that belong to “qualifying MNE groups” starting (in most cases) with 2024 taxation years. In principle, this tax is meant to apply to earnings otherwise taxed at a rate of less than 15%. However, under certain circumstances the earnings of Canadian entities, and as well as the earnings of their subsidiaries in other high tax rate jurisdictions, could be subject to top-up tax under these rules. The presenters will review certain aspects of the GMT Act, with a focus on practical examples that identify tips and traps for those trying to navigate the rules.
John D. Farquhar, Felesky Flynn LLP, Calgary
Tim Fraser, KPMG Canada, Vancouver
John’s practice covers a range of taxation law matters with a focus on corporate and international tax planning, mergers and acquisitions, corporate reorganizations and CRA audits. He maintains dual qualifications as a lawyer and as a CPA designated accountant. John has many years of experience serving both publicly and privately owned clients across a range of industries. Prior to joining the Felesky Flynn LLP, John was a member of an international accounting firm serving as a tax professional in both Australia and Canada. As an accomplished tax professional in both jurisdictions, he brings and unique and fresh perspective to tax law. John graduated with honours from the University of Melbourne where he holds a double degree in Commerce and Law.
Tim is a partner in KPMG’s International Corporate Tax practice in Vancouver, with over 15 years of Canadian tax experience, and more than 11 years advising multinational corporations and private equity enterprises, in numerous industries, on international and cross border taxation. Tim specializes in financing and structuring of investments outbound from Canada and inbound into Canada, inbound and outbound mergers, acquisitions and divestures, repatriation planning and restructuring of foreign affiliate groups. Tim also has extensive experience with the preparation of complex foreign affiliate surplus computations, and the interaction of the foreign affiliate rules with Canada’s CCPC regime. Tim has participated in numerous speaking engagements on international tax matters and has been a facilitator for CPA Canada’s In-Depth Tax Courses.
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