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For Canadians with $10M+ in digital assets, what strategies exist to arbitrage different tax rates between personal holdings, corporations, and trusts across tax years?
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What are the “GILTI” rules (Global Intangible Low Tax Income) that affect US citizens trying to use offshore corporations?
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What is the Section 85 rollover in Canada, and how does it allow Canadians to move crypto into a corporation without triggering immediate tax consequences?
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How does Canada’s capital gains inclusion rate work, and what changed when it increased to 67% for amounts over $250,000?
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What options exist for offshore asset protection trusts (Cook Islands, Cayman, Bermuda, Nevis, Panama), and why does Panama have favorable US treaties?
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Can non-US residents (UK, Canada, Australia, Europe, Dubai) use your services, and do you have local partners or recommendations for equivalent structures under foreign laws?