Eric has been practicing U.S. corporate and U.S. cross-border tax law for 20 years. Eric was born in the U.S. and graduated from law school there in 2000. He has been living in Vancouver, Canada for the past 13 years and frequently visits Calgary for client meetings and other business functions.
Eric advises Canadian and U.S. clients on a wide array of U.S. tax matters, including:
- Assisting Canadians investing in U.S. real estate with the U.S. Foreign Investment in Real Property Tax Act (“FIRPTA”) rules.
- Assisting U.S. persons in dealing with the U.S. controlled foreign corporation (“CFC”) rules.
- Assisting Canadian corporations and their U.S. minority shareholders to identify and manage passive foreign investment company (“PFIC”) issues.
- Assisting Canadians in dealing with Canada-U.S. tax treaty issues.
- Assisting Canadian corporations with filing U.S. federal and state corporate income tax returns and advising on sales and use tax matters.
- Helping Canadians with cross-border U.S. reporting and withholding tax issues.
- Assisting Canadian with structuring and financing business operations within the U.S., either through a branch of their existing Canadian entity or through a separate U.S. subsidiary.
- Advising Canadian businesses on issues dealing with cross-border mergers and acquisitions, such as providing U.S. tax due diligence services, structuring corporate acquisitions in a full or partial U.S. tax-free manner, advising clients on treating stock purchases as asset purchases for US tax purposes, and identifying and dealing with the various U.S. tax rules restricting the use of tax attributes following an acquisition.
- Assisting multi-national corporations in simplifying their internal corporate structure to help reduce cross border tax inefficiencies such as “sandwich” structures.