LEADING INDICATORS FOR THE NEED FOR CUTT SERVICES

1. Selling to a Related Cross-Border Entity: Recent rulings in both Canada and the U.S. have put many established transfer pricing policies into question.

2. Transferring Employees Across the Border: Employee transfers and payroll reporting requirements.

3. Presence in the Other Country: Cross-border corporate structures with an integrated perspective.

4. Excessive Debt Leverage: In such cases, the company may lose interest expense deductions.

5. Ownership of a Canadian Unlimited Liability Corporation: The withholding rate on dividends paid from Canada to the U.S. may increase from 5% to 25%.

6. Withholdings: Withholding regulations and requirements concerning payment for cross-border services.