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International

For families, founders, and enterprises with connections across borders, the legal and tax landscape is rarely straightforward. Residency changes, cross-border assets, multi-jurisdictional structures, and the movement of capital between countries all demand counsel that is technically precise, discreet, and properly coordinated. At LPN, our international practice is built on deep technical expertise and an extensive network of trusted legal and tax relationships across key jurisdictions — working alongside leading international counsel to deliver integrated, jurisdiction-aware solutions wherever our clients' interests arise.

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What distinguishes our international practice is our ability to hold the full picture together. Cross-border matters rarely sit neatly within a single discipline — they intersect tax, corporate, estate, and trust law simultaneously, often across multiple countries. Our role is to coordinate that complexity into a coherent strategy, ensuring that every dimension of a client's international affairs is addressed with the same care and precision we bring to our domestic mandates.

International Advisory
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International tax planning demands both technical rigor and creative counsel. We advise individuals, families, and privately held enterprises on the tax dimensions of living, investing, and doing business across borders — including the establishment of holding structures across multiple jurisdictions, intellectual property ownership arrangements, and the efficient movement of capital between countries including the strategic use of tax treaties and reciprocal agreements. Where clients have ongoing connections to multiple tax jurisdictions, we provide the coordinated, jurisdiction-aware advice required to manage those obligations with confidence.

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We also advise individuals and families navigating changes in residency — including pre-departure restructuring, deemed disposition planning, and the full range of personal and corporate tax considerations that arise when ceasing or establishing Canadian residency. Our approach is proactive and integrated, ensuring that the tax implications of international decisions are understood and addressed before they become problems.

Cross-Border Tax & Structural Planning
International Corporate, Estate & Trust Structures

Cross-border transactions and structures require careful attention to legal form, tax efficiency, and — where relevant — the privacy and confidentiality of the parties involved. We advise on the design and implementation of international corporate and holding arrangements, the establishment of cross-border trust and investment structures with succession and asset protection objectives, and the legal and tax dimensions of significant international transactions involving private companies, investment vehicles, and closely held groups.

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Our international corporate, estate and trust work addresses the particular complexity that arises when families, assets, and beneficiaries span more than one country. We advise on multi-jurisdictional estate plans, non-resident beneficiary arrangements, cross-border real estate holdings — including the Canadian tax implications of US 1031 exchange transactions — and the reporting and compliance obligations that attend international trust and investment structures. In every matter, our objective is a structure that is legally sound, tax-efficient, and practically durable across the jurisdictions involved.

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Our international mandates reflect the breadth and sophistication of the cross-border challenges our clients navigate. Representative engagements have included the design of an acquisition structure for a prominent online content provider with particular attention to the confidentiality and privacy of the ultimate beneficial owners; the establishment of multi-jurisdictional holding company structures to achieve tax efficiency across several countries; and the coordination of global tax strategy for a multinational corporation across multiple operating and holding jurisdictions.

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We have also advised on complex departure planning for high-net-worth individuals ceasing Canadian residency, including pre-departure restructuring and deemed disposition arrangements; the design of intellectual property holding regimes within cross-border corporate groups; cross-border repatriation strategies for income earned through Canadian operations; the structuring of an international investment fund acquiring a leading Canadian AI integrator; and the Canadian tax implications of US 1031 exchange transactions for clients with real estate holdings across multiple jurisdictions.

Representative Transactions
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