The Tax Advantages of International BusinessIn British Columbia, Canada

Global Chinese Financial Forum

December 3, 2009

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BRITISH COLUMBIA’S COMPETITIVE ADVANTAGES

BC is a strategic gateway to the Pacific Rim and the US. Sailing time from British Columbia ports is 2-3 days shorter than US ports.

Vancouver International Airport offers non-stops flights to major cities in Asia.

Hong Kong is serviced by 2-3 non-stop flights a day.

Strong Asian business and support networks.

Stable political environment

Foreign currency reporting

Ethnic diversity and established Asian communities

Labour talent pool of 2.4 million

Quality of living

Cluster of financial expertise

BC has no residency requirements for corporate directors and exemption of B.C. tax for qualifying foreign trade/exchange specialists.

Immigration encouraged

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THE IFA PROGRAM

The International Financial Activity (IFA) program is a unique tax incentive used to promote British Columbia (western most Province of Canada) as a location for investment.

The IFA program provides registered corporations with a refund of a corporation’s provincial tax (11% as of July 1, 2008) paid on income from qualifying international activities.

The legislative framework for the IFA program is the International Financial Activity Act (IFAA) of 2004.

In most cases, non-arm’s length as well as arm’s length transactions qualify.

A company can do business from any location in the Province—not only Greater Vancouver.

For non-residents transferred to BC to work in an International Financial Business (IFB), 75% of BC personal tax is refunded for 5 years.

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IFA PROGRAM AND RECENT TAX REDUCTIONS

Corporate taxes reduced in 2008 12% to 11%. Further reductions to 10% by 2011 planned.

In 2012, the combined corporate tax rate for British Columbia companies will be 25%.

For companies registered in the IFA Program, the rate will be 15%.

2009 19.0%2010 18.0%2011 16.5%2012 15.0%

General corporate income tax rate will be reduced to 15% by 2012.

Provincial

Federal

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Location Total Tax Index

Canada Average 86.4

Vancouver 77.0

Vancouver with IFC 65.0

Toronto 94.8

United States Average 100.0

New York 109.8

Japan Average 126.4

Fukuoka 125.6

Australia Average 114.6

Sydney 122.2

Germany Average 175.3

Frankfurt 182.4

VANCOUVER: LOW TAXES (TOTAL TAX COMPARISON, SERVICES)

Note: 2008 Total Tax Index compares total taxes (income, payroll, sales, property, and other statutory charges) imposed on a service business over a 10-year period based on KPMG’s 2008 Competitive Alternatives. Country indices are an average of cities in the study. Average US total tax is a baseline of 100.0 and other jurisdictions or cities are compared to this baseline.

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A QUALIFYING ENTITY

In 2004, all companies became eligible based on qualifying activities.

To register for the IFA program, a company must fulfill these requirements:

was incorporated in Canada and since incorporation has not been continued outside of Canada,

has a permanent establishment in British Columbia,

is not exempt from income tax under the Income Tax Act,

establishes and carries on an international financial business within 90 days of registration,

establishes and maintains a membership in the International Financial Centre British Columbia Society ($1,000 Annual fee plus 0.45% of qualifying income as a Participation assessment fee)

pay a one-time application and registration fee of $5,000.

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Management services Patents: Life science and green-relatedFilm distributionEquipment and data back-up

Treasury and cash management: short-term securities trading, intra-corporate loans and deposits, foreign exchange, managing investments and financial portfoliosFactoring and collecting trade accountsAsset management activities including managing investments and securities, providing financial advice, financial researchDealing in securitiesAdministrative support services related to financial activitiesInsurance, including captivesFinancial leasing

QUALIFYING ACTIVITIES

One side of the transactions is conducted with, for, or on behalf of a non-resident of Canada. In most cases, arm’s length and non-arms length qualify.

Financial Activities

Non-Financial Activities

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Leasing property to non-residents by way of a direct financing lease

Short-term securities trading by a non-financial corporation

Managing investments for non-resident persons.

Intra-corporate loans and deposits

Managing financial portfolios.

Providing financial advice.

Factoring and collecting trade accounts receivable.

FINANCIAL AND CORPORATE TREASURY

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Management services related to the business operations of a non-resident.

Strategic management services provided by the head office

Human resource services, such as payroll, benefits management, recruitment and selection, and training and development.

HEAD OFFICE ACTIVITIES

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TAX REFUND: FOR CORPORATIONS

A registered company can receive a 100% refund of BC corporate tax paid on qualifying IFB income.

Patent-related refunds are limited to 75% of BC corporate tax to a maximum of $8 million.

Refund is not taxable as income if election is made.

A refund is paid only after all British Columbia and federal income taxes for the taxation year are paid.

Returns must be filed within 18 months of the end of the taxation year.

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Specialists are entitled to receive up to 75% refund of BC tax on IFA eligible employment income for a maximum of five years. Maximum marginal tax rate drops from 43.7% to 32.675%.

IFA Specialists must be transferred from outside of Canada to provide a specific expertise and have an employment agreement in place prior to arriving in Canada.

The terms of the written contract of employment require that at least 70% of the individual’s working time is devoted to performing international financial activities for the corporation.

IFA SPECIALISTS

A company in the IFA program can apply to register an employee as an IFA Specialist.

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TAX REFUND: FOR IFA SPECIALISTS

75% of BC personal income taxes are eligible for a refund for IFA Specialists.

Refund is not taxable as income.

A refund is paid only after all British Columbia and federal income taxes for the taxation year are paid.

Returns must be filed within 18 months of the end of the taxation year.

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Use of IFC BC offers attractive tax rates of 19% (15% in 2012)

Proximity to US market/economy

Avoids complexity and tax risk associated with tax havens

Tax effective conduit to North America (similar for Ireland to Europe and Hong Kong to China)

SUMMARY

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The 2010 Olympic and Paralympic Winter Games are expected to generate up to $10.7 billion in economic activity.

It’s estimated 250,000 people will visit British Columbia in 2010.

Project-to-date venue construction expenditures now total $480.8 million, including highway improvements and the new RAV Canada Line.

2010 OLYMPICS

The 2010 Games will showcase British Columbia as a leading international business centre; a place where natural beauty and cosmopolitan living co-exist in a sustainable balance.

See you in 2010!

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T: 604.683.6627E: bflexman@ifcbc.com

Suite 1170 – Park Place666 Burrard StreetVancouver, BC Canada V6C 2X8

www.ifcbc.com

QUESTIONS AND ANSWERS

Bruce Flexman, President, IFC BC