4 Practical Structuring Considerations

Canadian Cross-Border Tax Planning · 4:02

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Lyrics

[Verse 1]
When you're running companies on both sides of the line
Canadian and US entities intertwined
There's a structure that's defensible and clean
The simplest approach you've ever seen

Your Canadian corp becomes your employer of choice
Pays your salary, gives your income a voice
Then it invoices the US side for your time
At arm's length rates that are perfectly fine

[Chorus]
Four corners of structure, keep it tight
Canadian corp pays you right
US entities pay for services rendered
Arm's length pricing, fully documented
IP in one place with licenses flowing
Cost deductible, profits knowing
Four corners of structure, that's the way
To keep the tax authorities at bay

[Verse 2]
US entities receive your services with care
Pay the Canadian corp for what you share
Intercompany agreements spell it all out
No questions left, no room for doubt

The Canadian corp employs you as an officer
Small business deduction makes taxes softer
While US costs stay deductible and clean
Best of both worlds in this tax machine

[Chorus]
Four corners of structure, keep it tight
Canadian corp pays you right
US entities pay for services rendered
Arm's length pricing, fully documented
IP in one place with licenses flowing
Cost deductible, profits knowing
Four corners of structure, that's the way
To keep the tax authorities at bay

[Bridge]
Intellectual property needs a home
Assign to one entity, let it roam
License to others or share the cost
Structure it right so nothing's lost

Document everything, make it real
What would strangers agree to in a deal
Consistency across the border line
Arm's length pricing every time

[Chorus]
Four corners of structure, keep it tight
Canadian corp pays you right
US entities pay for services rendered
Arm's length pricing, fully documented
IP in one place with licenses flowing
Cost deductible, profits knowing
Four corners of structure, that's the way
To keep the tax authorities at bay

[Outro]
Centralize income where you reside
Keep deductions on the US side
Four corners standing strong and true
Cross-border structure made for you

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