← Jobb

Canadian CPA or tax lawyer for cross-border holdco, Section 85 rollover and T2 compliance

Budget: $100.0 - $100.0 HOURLY / FULL_TIME ⭐ 5.00 (2) CAN

certified-public-accountant, corporate-tax, tax-law, international-tax-law

Preferred qualifications

  • Experience: Expert
Pre-revenue IP licensing company. Delaware corporation, sole shareholder and director resident in Alberta. An Alberta holding company is being incorporated to sit above the Delaware entity. I need one person to own the Canadian corporate tax side. SCOPE 1. Share structure recommendation for the Alberta company's Articles, drafted with a Section 85 rollover in mind, including whether preferred shares issuable in series are appropriate. Wording I can hand to a registry agent verbatim. 2. Section 85 rollover transferring the Delaware shares into the Alberta parent. Form T2057, elected amount, price adjustment clause, and the supporting valuation position. The principal asset is early-stage intellectual property with no revenue. 3. Whether the Delaware subsidiary requires Alberta extra-provincial registration. 4. Central management and control analysis for the Delaware corporation, given the sole director is resident in Alberta. 5. Corporate tax setup and first-year compliance: T2, Alberta AT1, GST and payroll only if applicable. 6. Ongoing annual compliance, quoted separately. The Alberta incorporation itself is handled and is not part of this scope. WHAT YOU WILL BE WORKING WITH Records are organised and ready: complete corporate documents, general ledger, trial balances and financial statements. There is one known equity misstatement, already identified and instructed for correction. You will be told about it up front rather than discovering it. TIMELINE Items 1 and 3 within one week of engagement. Item 2 within six weeks. HOW THIS STARTS The engagement begins with a paid first task covering items 1 and 3. Items 2 and 5 are quoted and awarded after that is delivered. All screening questions must be answered in full.
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