Principal - Canadian Cross Border Tax

Smythe LLP•Vancouver, BC

4h•CA$170,000 - CA$220,000•Hybrid

About The Position

Smythe LLP is seeking a collaborative, technically strong, and people-focused Principal – Canadian Cross Border Tax to join our growing Cross Border Tax practice in downtown Vancouver. This is an exciting opportunity for an experienced Canadian tax professional to take a leadership role in our International Tax practice, advising Canadian companies and multinational groups on complex tax matters. You’ll work closely with clients, Partners, Managers, and professionals across jurisdictions to identify opportunities, solve complex tax issues, and deliver practical, commercially focused advice. Beyond technical expertise, we’re looking for someone who enjoys developing people, building trusted client relationships, and contributing to the growth of a practice. For the right individual, this role offers a clear pathway to Partnership. As a principal, you will lead complex Canadian cross border tax engagements while taking increasing responsibility for clients, teams, and practice development.

Requirements

CPA designation.
5+ years of Canadian tax experience, with a focus on cross-border taxation.
Experience advising Canadian subsidiaries of multinational groups and/or Canadian companies with foreign operations.
Strong knowledge of Canadian cross border tax principles and the ability to apply them to practical client situations.
Intercompany financing and thin capitalization
Part XIII and Regulation 105 withholding
Foreign affiliate rules, surplus calculations, and PLOI elections
FAPI, upstream loans, and shareholder loan rules
Foreign affiliate dumping and CRIC considerations
Treaty-based withholding and foreign exchange issues
Foreign reporting and EIFEL
Ability to identify issues independently, perform technical analysis and calculations, and determine when complex matters require escalation or specialist input.
Experience preparing or reviewing technical memoranda, calculations, elections, and compliance filings.
Strong engagement management skills and the ability to manage multiple priorities and deadlines.
Excellent communication skills, with the ability to explain complex tax matters clearly to clients and colleagues.
Demonstrated ability to mentor, coach, and develop tax professionals.
Strong client relationship-building skills and a commercial mindset.
A collaborative, entrepreneurial, and growth-oriented approach.

Responsibilities

Advise Canadian companies and multinational groups on complex inbound and outbound tax matters.
Lead cross-border tax planning, advisory, and compliance engagements from issue identification through implementation.
Advise on EIFEL, FAPI, foreign affiliates, surplus calculations, withholding tax, treaty interpretation, foreign reporting, intercompany financing, thin capitalization, shareholder loans, and foreign exchange.
Address complex matters involving FAD, CRIC rules, upstream loans, PLOI elections, and other Canadian cross border tax provisions.
Prepare and review technical analysis, calculations, elections, memoranda, and compliance filings.
Identify Canadian tax implications of cross-border transactions, reorganizations, financing arrangements, and multinational structures.
Coordinate with foreign advisors and tax teams on multi-jurisdictional matters.
Act as a trusted client advisor, providing practical and commercially focused tax solutions.
Lead, mentor, and develop high-performing tax teams while reviewing work for technical quality.
Work closely with Partners on complex engagements, client strategies, and solutions.
Support business development, client growth, proposals, and practice-building initiatives.
Contribute to the continued growth and development of Smythe’s Canadian Cross Border Tax practice.