Victor & Gold - Jonathan Levy, MBA, CPA, CA

Notepad:
Jonathan Levy, MBA, CPA, CA

Dear Clients:

date: 28/09/07

Canada's government signed a new Protocol to the Canada-U.S Tax Treaty, which:

- eliminates withholding taxes on cross-border interest payments;

- extends treaty benefits to limited liability companies;

- allows taxpayers to require that certain key double tax issues, such as transfer pricing, be settled through arbitration;

- ensures that there is no double taxation on emigrants’ gains;

- gives mutual tax recognition of pension contributions;

- clarifies how stock options are taxed.

Please contact me if you require more information on these changes to the Canada US Tax Treaty.

date: 12/06/06

Recently Victor & Gold was engaged by several American groups to assist in structuring their expansion into Canada.

One solution that works well for Americans is to incorporate the Canadian business in either an Alberta or a Nova Scotia Unlimited Liability Corporation ("hybrid entities").

Hybrid entities offer significant advantages to US investors. While they function in Canada as normal corporations, they are also considered flow-through entities by the IRS. This means that start-up losses can be flowed through to the US investors, who can then apply these losses to other sources of income.

A hybrid entity can also give US taxpayers with a subpart "f" attribution problem access to foreign tax credits, which would otherwise be trapped in a convential Canadian corporation.

If you are an American investor, call me to discuss if a "hybid entity" can work for you.

date: 13/11/05

Our firm is conducting a consulting mandate for Microsoft Corporation. The project includes assisting Microsoft develop and test a software product that will be introduced to the Canadian market.

We have extensive experience in advising businesses on software selection. Call me if you wish to review your business software requirements.


	Contact Jonathan Levy
	Jonathan Levy

Partners:

F. Leboff

E. Victor

B. Shiller

J. Levy

S. Plante

K. Shemie

Jonathan Levy, MBA, CPA, CA

Areas of Professional Expertise

Corporate finance
Financing of small and medium sized companies
Acquisitions
Capital budgeting
Forecasting and banking
Management consulting
Corporate restructuring
Profitability analysis
Strategic planning
Development and maintenance of computer and management information systems
Personal and corporate income tax planning

Education & Designations

Bachelor of Arts - Honours Program (Political Science and Sociology) (McGill University)
Master in Business Administration (Concordia University)
Graduate Diploma in Public Accountancy (McGill University)
Chartered Accountant designation (Québec, Ontario)
Certified Public Accountant (CPA) designation (Illinois)

Achievements

Lecturer at McGill University in the areas of Finance and Tax
Partner responsible for the firm's marketing program

Memberships

American Institute of Certified Public Accountants (AICPA) [CPA]
Ordre des comptables agréés du Québec [CA]
Canadian Institute of Chartered Accountants
Institute of Chartered Accountants of Ontario
Society of Trust and Estate Planners (STEP)
Accountants Discussion Group