March 2026
KFG Law
Tax & Business Focus
About the Author
With over 20 years of experience, Marc has established himself as a leading authority in domestic and international tax planning.
Marc acts as a strategic tax and corporate advisor to a diverse roster of clients, including entrepreneurs, high-net-worth individuals, owner-managed businesses, established corporations, and family offices. His clients rely on his sophisticated and practical counsel to help them achieve complex business and personal objectives.
He has extensive experience advising on tax-driven corporate reorganizations, cross-border transactions—particularly between Canada and the United States—and tax planning for multinational corporations. Marc also provides comprehensive succession and estate planning services for family businesses, including those involving Canadian residents and U.S. citizens, family trusts, offshore structures, estate administration, and post-mortem tax planning designed to minimize multiple levels of taxation.
In addition, Marc represents clients in all aspects of tax controversy matters, including Canada Revenue Agency audits, appeals, voluntary disclosures, and negotiated tax payment arrangements.
While his practice spans a wide range of corporate matters, Marc’s primary focus is on complex mergers, acquisitions, and dispositions of businesses, private equity-sponsored transactions, and private placements related to the acquisition of operating businesses and real estate portfolios. He also regularly advises on sophisticated business transactions, including corporate financings, real estate-based partnership syndications, and shareholder agreements.
About KFG Law
KFG Law is a full-service boutique law firm with offices in Toronto.
The firm provides clients with a broad range of legal services and deep expertise across key practice areas, including corporate and commercial law, mergers and acquisitions, tax, estate planning and administration, banking and financing, real estate, commercial litigation, estate litigation, employment, and securities law.
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Please email Agnesa Mauro at agnesa@kfglaw.ca
CRA Business Registration Moves Fully Online – What Foreign-Owned Businesses Need to Know
At KFG LLP, we deliver sophisticated legal counsel to a wide range of business clients, from small, owner-operated enterprises and their principals to large multinational corporations, limited partnerships, private equity firms, and real estate syndications, in both domestic and cross-border contexts. We offer creative, tax-efficient, and cost-effective solutions to complex tax and business law matters, including the design and implementation of corporate structures.
In 2025, the Federal Government announced a digital transformation initiative aimed at reducing regulatory burden and making government services more cost-effective. As part of this effort, the Canada Revenue Agency (CRA) discontinued business (tax) account registration by phone. All new registrations must now be completed through the CRA’s Business Registration Online (“BRO”) platform.
What This Means for Businesses
The transition to online registration has clear benefits—greater efficiency, digital records, and reduced phone-based processing—but there is an important limitation:
- Eligibility Restriction: The BRO is only available if at least one corporate director has a Canadian Social Insurance Number (SIN).
- Alternative: Businesses without a Canadian director must file a paper RC1 form, which is time-consuming and significantly slower compared to near-immediate phone processing.
Delays in obtaining a federal business number, payroll account, or GST/HST account can cascade into operational challenges, including:
- Opening bank accounts
- Hiring and paying employees
- Beginning commercial operations
Who Is Most Affected?
- Foreign-owned businesses establishing Canadian subsidiaries often face delays because Canadian directors may not be readily available.
We often represent clients establishing Canadian subsidiaries to make capital investments or hire Canadian employees. While incorporation can still be completed within hours, the CRA’s online registration may now take six to eight weeks before businesses can begin operations.
Potential Solutions and Outlook
While the government’s digital modernization is commendable, unintended consequences like operational delays may arise. To mitigate these impacts, businesses should plan for business account registration timelines when establishing new operations.
Key Takeaways
- Phone registration ended: All businesses must use BRO or submit paper forms.
- BRO limitations: Requires a Canadian SIN for at least one corporate director.
- Paper filing delays: Registering via the paper RC1 form is time-consuming and significantly slower compared to near-immediate phone processing.
- Foreign subsidiaries are most affected: Operational delays may stretch 6–8 weeks.
- Strategic planning required: Businesses should account for these delays in investment and hiring timelines.
For expert guidance:
Keslassy Gelfand Freedman LLP has extensive experience helping foreign businesses establish Canadian subsidiaries and navigate CRA registration challenges. Contact us to ensure a smooth and timely setup for your Canadian operations.
This publication is intended for general information purposes only and should not be relied upon as legal advice. ©KFGLAW.CA