Advise clients on the best course of action using insights from past cases.
Assess the accuracy of your characterization and calculate your risk.
Ensure your position is sound with an unbiased third-party report.
Do the operations of a non-resident enterprise constitute carrying on a business in Canada such that income from that business is taxable in Canada?
Does a United States resident have a “permanent establishment” in Canada pursuant to paragraph 1 or paragraph 5 of Article V of the Canada-US Tax Treaty?
Is a worker an employee or an independent contractor for tax purposes?