Expert Access Seminar Series:

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1 Expert Access Seminar Series: Expanding to the US October 12, 2011

2 Introductions Melanie Kurk, Senior Manager Melanie has CA (Ontario) and CPA (Ohio) designations as well as a Bachelor of Arts in Business-Accounting and a Masters of Science in U.S. Taxation. Melanie has worked in PwC's US/International Tax group for more than 15 years. Prior to that, Melanie worked in Cleveland, Ohio, both in tax in public accounting and in industry. Melanie specializes in assisting clients with U.S. federal and state taxation matters relating to the technology industry and ownermanaged companies conducting business in the U.S. PwC 2

3 Course Objectives - US Tax Create awareness of circumstances that give rise to U.S. federal and state taxation for Canadian businesses operating in the U.S. Create a basic understanding of U.S. federal income taxation of non-residents and impact of the Canada- U.S. Treaty Create a basic understanding of various types of state taxes in the U.S. - income, franchise, margins, and sales tax PwC 3

4 Agenda 1. U.S. federal taxation of non-residents Taxation of investment income (Fixed or Determinable, Annual or Periodic ( FDAP )) Taxation of business profits (Effectively Connected Income (i.e. Trade or business income)) Branch vs. Subsidiary 2. U.S. state taxation Nexus Types of Taxes Other issues PwC 4

5 U.S. federal taxation of non-residents Taxation of investment income (FDAP)) PwC 5

6 U.S. taxation of non-residents Fixed or Determinable, Annual or Periodic Income ( FDAP ) U.S. source gross investment type income Taxed at 30% rate Reduced under applicable treaty Interest, dividends, rents, royalties, etc. Must be U.S. source PwC 6

7 Withholding tax rates under the Canada-U.S. tax Treaty Cross-border charges Dividends 5 or 15% Interest 0% Fifth Protocol: arm s length 0%; related party phase-out 7% in 2008, 4% in 2009, 0% thereafter; prior to Fifth Protocol: 10% Royalties 0 or 10% Rents (real property) 30% (or net election) Rents (other) 10% Management charges 0% PwC 7

8 Request for reduction in withholding tax rates under Treaty Form W-8 BEN Individuals, Corporations Form W-8IMY Partnerships, Trusts Form W-8ECI Trade or Business in U.S. PwC 8

9 U.S. taxation of non-residents Taxation of business profits connected with a U.S. trade or business PwC 9

10 Liability for U.S. taxation A Canadian company is subject to U.S. tax on business profits in the U.S. if: Carrying on U.S. trade or business; and Has income effectively connected with U.S. trade or business. UNLESS: Canco can obtain relief under the Canada-U.S. Tax Treaty ( Treaty ). (i.e.canco does not maintain a U.S. permanent establishment per the Canada-U.S. Tax Treaty ( Treaty ) AND is eligible to claim Treaty benefits (need to analyze the Limitation of Benefits Article XXIX-A of the Treaty). PwC 10

11 U.S. Federal Taxation Carrying on U.S. trade or business Very low threshold test Determined on a case-by-case basis Canco may be deemed to be carrying on U.S. trade or business in the U.S. if Canco regularly and continuously transacts business in the U.S. (e.g. frequent attendance at trade shows where sales made to U.S. customers) PwC 11

12 U.S. Federal Taxation Effectively Connected Income (ECI) U.S. trade or business generates U.S. source income Income from services Sale of inventory PwC 12

13 Canada U.S. Treaty Permanent Establishment ( PE ) Canadian company s business profits are subject to U.S. taxation to the extent attributable to a U.S. PE. Definition of PE: Canada-U.S. Treaty defines PE as specifically including the following (among other items): 1. A fixed place of business in the U.S. that includes: office, a place of management, construction site lasting at least 12 months; 2. An employee who has, and habitually exercises, the authority to conclude contracts in the name of the Canadian principal. 3. Services PE (discuss later in the slide) PwC 13

14 Canada-U.S. Treaty Permanent Establishment (PE) (cont d) Canada U.S. Treaty specifies that PE does not include: A warehouse or use of facilities for storage, display, or delivery or processing by another person; The purchase of goods or collection of information; Advertising; Use of dependent sales representatives (employees of Canco) without the authority to contract; A U.S. subsidiary; or Independent agents of brokers acting in the ordinary course of their business. PwC 14

15 Canada-U.S. Treaty-New Deemed Services PE A PE in the U.S. is deemed to exist if either Test 1 or Test 2 is met. Test 1 if both conditions are met: PwC 15 Services performed by Canadian individual present in the U.S. for >183 days in any 12-month period; and In the same period, more than 50% of gross active business revenues are derived from services performed in the U.S. Test 2 if both conditions are met: Services provided by Canadian company in the U.S. for >183 days in any 12- month period; and Services provided with respect to same or connected projects for customers who are either resident or have a PE in the U.S. and the services are provided in respect of that PE. Effective date Issue for service businesses (e.g. consulting, training, engineering et c.) with long-term contracts.

16 Employee Filing Requirements Application of Treaty Exemption available if meets criteria of Article XV, Canada-U.S. Tax Treaty (Treaty): Remuneration <$10,000USD; or Present in the U.S. in any 12 month period beginning or ending in the fiscal year for <183 days and the remuneration is not paid by or on behalf of a person who is a resident of the U.S. and is not borne by a permanent establishment (PE) in the U.S. Not all states follow the Treaty File appropriate personal tax forms (e.g. Forms 1040, 1040NR, 8823) Watch U.S. federal, states, city, payroll withholding, and FICA taxes PwC 16

17 Canada - U.S. Treaty Permanent Establishment (PE) E-Commerce issues: Computer equipment (i.e. a server), owned or leased by Canco located in the U.S. may constitute a U.S. PE (including automated equipment not requiring on-site personnel. An internet web-site does not constitute a PE. A web-hosting arrangement generally does not result in a PE for enterprise paying for space on a server it does not own. For equipment to constitute a PE it must be fixed for a sufficient period of time (e.g. 6 months). ISP not a PE of an enterprise that conducts business through a web site hosted on a server owned by the ISP. PwC 17

18 Canada-U.S. Treaty Permanent Establishment (PE) (cont d) If no U.S. PE exists: Canco claims treaty protection by filing a U.S. Treaty-based federal return on Form 1120F and attaches Form Benefits of filing a U.S. Treaty-based return 1. Penalty for failure to disclose is $10,000 per instance. Increased IRS scrutiny of Treaty-based returns and nonfilers). 2. A U.S. Treaty-based return serves as a protective election. Reserves the right to claim and credits against income if the IRS determines PE exists. PwC 18

19 U.S. Federal Taxation - Summary No U.S. trade or business Taxed on investment income only 1 Canco No PE Business profits exempt under Art. VII U.S. trade or business 1 Investment income (interest, dividend, etc.) Subject to withholding tax Yes PE Canco taxed in U.S. on business profits PwC 19

20 U.S. Federal Taxation - Branch If U.S. PE Exists: U.S. branch income is subject to U.S. corporate income tax at graduated rates ranging between per cent. Allocation of revenue and expenses to U.S. branch is essentially cost accounting exercise. In lieu of withholding tax on a dividend, the IRS imposes complex system of branch taxation on two separate tax bases: Profits from Canco s branch operations that are deemed repatriated from the U.S. under the branch profit tax rules; and Excess interest that is apportionable to income of Canco. PwC 20

21 U.S. Federal Taxation - Branch Branch profits tax Applied to after-tax earnings to the extent that Canco does not reinvest these earnings in the U.S. branch. IRS imposes the branch profits tax at 30% (reduced to 5% US- Canada Treaty) and is in addition to the regular corporate income tax. Canada-U.S. Treaty and U.S. domestic tax law provides for exclusion from branch profit tax on first CA$500,000 of branch s income. PwC 21

22 U.S. Federal Taxation - Branch Advantages Start up losses of the U.S. branch are deductible against Canadian taxable income. Disadvantages U.S. transfer pricing rules do not apply to U.S. branch (uncertainty involving cost allocations). U.S. branch, as non-corporate entity, cannot deduct payments for royalties, management fees or interest to its Canadian headquarters. Inability for Canadian tax purposes to transfer assets of U.S. branch to U.S. subsidiary on tax deferred basis. State tax return considerations. PwC 22

23 U.S. Federal Taxation using a U.S. Subsidiary General overview Two levels of tax: corporate and shareholder Taxable income of U.S. Sub subject to corporate income tax rates ranging from 15 to 35 percent. US Sub able to deduct payments made to Canco for royalties (subject to withholding tax) and interest. Payment of management fees by U.S. Sub to Canco will not incur withholding tax. U.S. Sub incurs 5% withholding tax when repatriating cash dividend to Canco. Ensure all U.S. activities conducted through U.S. subsidiary to avoid inadvertent U.S. PE. PwC 23

24 U.S. Federal Taxation using a U.S. subsidiary (cont d) Distributions from U.S. subsidiary to Canco Concept of earnings and profits ( E&P ) Cash distribution to extent that E&P (first current, then accumulated) is a dividend and subject to 5% U.S. withholding tax Distributions in excess of E&P are tax-free return of capital of U.S. Sub Any excess in return of capital is a capital gain Financing a U.S. subsidiary Debt vs. Equity Earnings stripping rules and debt-equity ratio of 1.5:1 (safe harbor) PwC 24

25 U.S. Federal Taxation Pros & Cons of a U.S. Subsidiary Advantages of a U.S. subsidiary PwC 25 Accounting is simplified (avoid branch accounting); Possible to delay withholding tax until a distribution is made. Possible to avoid the 5% withholding tax on dividends upon liquidation. Financing options available. Possible to deduct various intercompany charges (may be subject to withholding tax). Business reasons a U.S. subsidiary preferred in the U.S. market place. Disadvantages of a U.S. subsidiary U.S. losses cannot be deducted against Canadian source profits.

26 U.S. Federal Taxation Where to incorporate a U.S. subsidiary? Why Delaware is popular state of incorporation: Delaware law permits anonymity and does not require either the disclosure or publication of the names of shareholders. One person can hold all corporate offices and be the sole director. That person need not be a shareholder. Annual corporate franchise tax in Delaware is as low as $50 per year. Delaware does not require that any shareholder meetings occur in Delaware or that corporate records be maintained in Delaware. Delaware s Courts have reputation of being pro-business. 26

27 U.S. Federal Taxation Where to incorporate a U.S. subsidiary (cont d) Delaware does not have a corporate income tax for corporations not transacting business in State of Delaware. Shareholder and director meetings are not necessary as Delaware permits shareholders and directors to act by written unanimous consent. Delaware law permits special provisions in By-Laws and Certificate of Incorporation that will exculpate officers and directors from personal liability. No shareholder consent required to make or alter by-laws. Delaware does not require shareholders to be either U.S. citizens or residents. Delaware does not require minimum capital. 27

28 Transfer Pricing Rules The intercompany transactions between Canadian and a U.S. subsidiary must be arm s length Contemporaneous documentation is required Where executives are employed by one legal entity, but perform work that benefits a related entity in another country, transfer pricing rules require a service charge between the entities Often, management-type services are charged on a cost-plus basis, where the plus (if any) is an arm s length profit mark-up; some services may not require a mark-up Where mark-ups are required, these are usually benchmarked against profits earned by comparable independent service providers PwC 28

29 Example number one: Cda U.S. CANCO (e-business) CANCO contracts with all U.S. customers USCO U.S. customers CANCO bears risk of non-performance through contracts with U.S. Customers. Contract-manufacture or sales company relationship between CANCO and USCO. Compensate USCO for services (cost + %). 29

30 Example number two: Cdn SH # 1 Cdn SH # 2 Cdn SH # 3 CANCO Cda U.S. Management Fee Distribution Agreement Royalty USCO PwC 30

31 U.S. State Tax Issues PwC 31

32 Agenda Current state tax environment International treaties Nexus what is it? State income tax Sales and use tax Franchise tax Non-traditional state taxes (Michigan, Ohio, Texas) Other state tax issues PwC 32

33 Current State Tax Environment U.S. states are on verge of bankruptcy and are looking for ways to reduce or eliminate cash shortfall. In order to raise more revenue: States have become more aggressive in catching taxpayers that are non-compliant; Some states are changing from an income tax to a gross receipts tax; Some states have broadened the tax base; and States are requiring unitary or combined returns. PwC 33

34 State Treatment of U.S. Tax Treaties States are not party to or bound by tax U.S. Treaty provisions. Examples of states that do not follow the Canada-U.S. Treaty: Arizona, California, New Jersey, New York, Pennsylvania. Others do not follow due to franchise/excise component: Kentucky, Massachusetts, Ohio. Examples of states that do follow the Treaty: Florida, Illinois, Maine, South Carolina. PwC 34

35 Nexus what is it? Differs from PE concept. A state has jurisdiction to tax a corporation organized in another state only if the out-of-state corporation s contacts with the state are sufficient to create nexus. Physical presence within a state is an essential prerequisite to establishing nexus (e.g. Footprint). Differs for each type of state tax income tax, sales tax, franchise tax. PwC 35

36 U.S. State Income Tax PwC 36

37 Types of State Tax State income tax nexus State s power to tax limited by the U.S. Constitution, PL , state constitutions and respective statutes. State tax rates range from 0% to 11%. Highest state tax nexus threshold. Income tax nexus created by physical presence of employees services such as training, consulting, repair/maintenance. maintaining property in-state (e.g. inventory, owned or leased property). PwC 37

38 Nexus Protective Activities PL U.S. federal law (does not apply to non-u.s. corporations) Applies to sales of tangible personal property only. Does not apply to sales, franchise and other taxes unless the state so chooses. Prohibits income tax if in-state activities are limited to mere solicitation of sales of tangible personal property, and orders are approved and shipped from outside the state. PwC 38

39 Advanced Nexus Concepts Agency nexus independent contractors Example Canco conducts business through independent agents. Does use of independent agents, rather than employees allow corporation to avoid nexus? Scripto case critical issue is whether the activities performed in the state by the independent contractors on behalf of the taxpayer helped establish and maintain a market for Scripto goods in this state. Florida Supreme Court held yes and Scripto had nexus in Florida. Public Law and independent contractors. Watch-out for affiliate / agency nexus. PwC 39

40 Advanced Nexus Concepts (cont d) Economic nexus General rule is physical presence. Geoffrey v. South Carolina held that a Delaware trademark holding company that licensed its intangibles for use in South Carolina had nexus for income tax purposes despite lack of any tangible property or employees in South Carolina. Geoffrey was trademark holding company for toy retailer Toys R Us. Geoffrey domiciled in Delaware and had license agreement with South Carolina retailers allowing them to use the Toys R Us trademark. PwC 40

41 Advanced Nexus Concepts (cont d) Economic nexus (Cont d) Court held licensing intangible for use in the state was sufficient to satisfy nexus requirements for South Carolina. Created nexus because court held intangibles were integral part of a business carried on within the states. Besides South Carolina, other states have adopted the Geoffrey rule in their state statutes for example New Jersey, Florida and Massachusetts. PwC 41

42 Common Nexus Creating Activities for State Income Tax Sales of any services Resident employees (unless meeting certain exemptions) Consigned inventory in a state Demo equipment at a customer site Tooling, dies and special tools in a state Rented space, even shared space, including servers Quality control and inspection activities Warranty or repair services, even by third party Installation/implementation services (e.g., hardware/software) PwC 42

43 US State Sales Tax PwC 43

44 Sales Tax Imposed by 45 states, and 7,000 + local jurisdictions Sales tax rates range from 0 to 11% Major source of revenue for most states Little conformity or consistency Not Treaty protected Not Public Law protected PwC 44

45 Sales Tax Cont PwC 45 When is sales tax imposed? Low nexus threshold Transaction tax - Imposed on sale/transfer of title and/or possession of tangible personal property and specified services. Who is liable for the tax? Purchaser is liable for the tax Seller is agent of the state in collecting the tax Seller and buyer share joint and several liability for remitting tax to the state Contractual language placing sales tax burden on purchaser irrelevant to state tax authorities Compliance is often required even if no tax is due

46 Sales tax Possible exemptions - exempt transactions and customers Exempt transactions resale, manufacturing. Exempt customer sale to government agencies or non-profits. Relevant resale/exemption certificates needed and kept on file may obtain blanket certificates. Some state governments don't issue certificate - purchase order sufficient. Exemptions vary from state to state. Returns may be required even if no tax due. Failure to file sales tax returns exposed to penalties (most based upon sales tax owing) + statute of limitations is open. PwC 46

47 Top Sales Tax Oversights 1. Activities conducted by third parties can create nexus. 2. Nexus can exist even if no PE under Canada U.S. Treaty. 3. Returns may be required even if no tax is due. 4. Failing to register for sales tax with state tax authorities. 5. Not securing exemption certificates/resale certificates from customers. 6. Not collecting sales tax or, worse, not remitting collected sales tax. PwC 47

48 Sales Tax & Software canned vs. custom Custom designed software generally treated as a service for state sales tax purposes. Sales tax will generally not apply to customer designed software, regardless of format of transfer. Canned software - generally treated as tangible personal property for state sales tax purposes. If the canned software is NOT transferred electronically, it is subject to sales tax. If transferred electronically, it is generally exempt from sales tax, but need to check each state. PwC 48

49 Sales Tax & Software canned vs. custom Example A customer is considering purchasing software from CANCO. The total software package combines designed software used in conjunction with canned software. The custom designed software is 65% of the package and the canned software is 35%. 1. Is the service for developing custom software a taxable transaction? 2. Is the canned software taxable? 3. If the systems are billed together, does the presence of the canned software affect the taxability of the customer software? PwC 49

50 US Franchise Tax PwC 50

51 Types of Tax Franchise/capital tax Privilege tax Generally based on capital stock or net worth Lowest nexus standard Qualifying or registering to do business is a legal act Rates vary PwC 51

52 Non Traditional State Taxes PwC 52

53 Types of Tax Non traditional state taxes Michigan Business Tax Ohio Commercial Activity Tax (CAT) Texas Margins Tax PwC 53

54 Non Traditional State Taxes Michigan Business Tax ( MBT ) Effective January 1, 2008 replaced SBT Combined filing required The MBT consists of : (1) Business income tax BIT is imposed on taxpayers with "business activity" in the state. Business activity is defined broadly for this purpose. BIT equals 4.95% of a taxpayer's business income tax base, which is the portion of U.S. federal taxable income derived from business activity with certain modifications. and PwC 54

55 Non Traditional State Taxes Michigan Business Tax (cont d) (2) Modified Gross Receipts Tax The GRT is 0.8% of a taxpayer's gross receipts tax base, which generally includes gross receipts less purchases. The GRT is imposed on taxpayers with Michigan nexus ( bright-line test ): the taxpayer has physical presence in Michigan for more than one day in the year; OR actively solicits sales in Michigan and has Michigan-source gross receipts of $350,000 or more in the year. Foreign Reciprocity Exemption for Treaty Based Filers. PwC 55

56 Non Traditional State Taxes Michigan Business Tax (cont d) Updates PwC 56 Effective 1/1/2012, Michigan Corporate Income Tax (CIT) will replace the MBT, except for certain businesses that wish to retain certain certificated credits. The CIT is comprised of three separate taxes: a corporate income tax, a premiums tax on insurance companies, and a franchise tax on financial institutions. Similar bright-line tests apply as that of MBT The CIT tax base is federal taxable income subject to specified additions and subtractions. CIT rate is 6% of the CIT tax base after allocation or apportionment.

57 Non Traditional State Taxes Ohio Commercial Activity Tax The Ohio Commercial Activity Tax ("CAT") is an annual privilege tax measured by "taxable gross receipts" from most business activities. The CAT applies to gross receipts sourced to Ohio. Most receipts generated in the ordinary course of business are subject to the CAT. The CAT applies to most businesses including but not limited to retail, wholesale, service, manufacturing, and other general businesses. CAT return prepared by taxpayer. PwC 57

58 Non Traditional State Taxes Ohio Commercial Activity Tax (cont d) An out-of-state business is required to register and pay the CAT if the business meets any of the following: Taxable gross receipts in the year are at least $500,000 Property in the state during the year is at least $50,000 Payroll in the state is at least $50,000, or Has at any time during the year within the state of Ohio at least 25% of its total property, payroll or total sales. The tax was phased in over 5 years. It was fully phased after March 31, No Ohio Franchise Tax filings starting with 2010 due to CAT replacing it. PwC 58

59 Non Traditional State Taxes Texas Margin Tax Effective January 2007-replaced Franchise Tax. Calculation of the tax: Step 1 - determine the "taxable margin". "Taxable margin" is the lower of (1) 70% of total revenue of the business;(2) total revenue of the business minus COGS; or (3) total revenue of the business less compensation and benefits. Step 2 - application of the rate the tax rate on the "taxable margin is 1% for most business. Business primarily engaged in wholesale or retail will apply a tax rate of.5%. Entities with gross revenues less than $300,000 or tax liability of less than $1,000 will not be taxed. De-facto follows the Treaty. PwC 59

60 Other US State Tax Issues PwC 60

61 Risk of Non-Filing Reps and warrants for financing or funding Financial statements may be incorrect If non-filing, statutes of limitation do not start running Need state tax clearance to spin off, sell or IPO the U.S. operations May need tax clearance for preferred vendor status Officer liability for some types of tax Penalties and interest can be substantial PwC 61

62 How Canadian Companies Get Caught Information sharing Request for websites on tax return forms Customs activity Nexus squads/discovery activity IRS and state memos of agreement Internet browsing California, New Mexico Customer audits Weigh stations Nexus mailings/questionnaires PwC 62

63 PwC 63

64 Technology Industry Specific Issues Leasing a server in a state Stored inventory or consigned inventory Contracts including software, services and maintenance Contractually assigning sales tax Downloaded or digital delivered product Services in state such as training, consulting, or installation Maintenance contracts PwC 64

65 The Perfect World State Tax Progression Qualify with Secretary of State to do business Register with Department of Revenue for state income, employment, franchise and/or sales tax, if applicable Begin conducting business in-state Determine nexus and tax filing requirements Collect and remit sales tax, if required File income tax returns on a timely basis Review business activity on a regular basis PwC 65

66 Nexus Quiz CANCO s only activity in Michigan is sales people entering the state to sell product. Contracts are concluded and approved and fulfilled from Canada. Does CANCO have nexus? CANCO has a US domestic subsidiary which houses US resident employees. However, the signatory party on the contracts is CANCO and CANCO employees help with implementations in the US. Does CANCO have nexus? CANCO has demo equipment at client locations in various states. Does CANCO have nexus? PwC 66

67 Nexus Quiz (cont d) CANCO sells software (tangible personal property) but uses either CDN or contract personnel to train and handle implementation at client locations. Does CANCO have nexus? CANCO uses independent salespeople s home addresses on their website as US locations. Does CANCO have nexus? CANCO provides services via internet or web based product but has sales people traveling around US as part of the marketing program. Does CANCO have nexus? CANCO says that title passage to products sold into the US takes place in Canada, however, CANCO is the importer of record for US Customs purposes. Does CANCO have nexus? PwC 67

68 Contact any one of our local PwC tax specialists for more information: Andy McAskile Partner Debra Baker Partner Nexus Navigator Nadia Manin Associate Partner Melanie Kurk Senior Manager Helping Canadian companies navigate the complex realities of US state and local taxes 48 States Face Budget Shortfalls in Fiscal How can it impact you? WA OR ID CA NV UT MT WY CO ND SD NE KS MN WI IA IL MO NY MI PA IN OH WV KY VA ME VT NH MA RI CT NJ DE MD AZ NM OK TX TN AR MS AL LA NC SC GA AK FL HI 2009 PricewaterhouseCoopers LLP. All rights reserved. PricewaterhouseCoopers refers to PricewaterhouseCoopers LLP, an Ontario limitedliability partnership,or, as thecontextrequires, thepricewaterhousecoopersglobalnetworkorothermemberfirmsofthenetwork, eachofwhichisaseparate and independentlegal entity. PwC 68

69 Impact of Doing Business in the US on Deals October 12, 2011

70 Introductions Craig Hanna, Vice President PricewaterhouseCoopers Corporate Finance LLC* & PwC Deals Craig is a Vice President with PwC Corporate Finance based in Toronto. Corporate Finance is within the PwC Deals practice that includes transaction services, valuations, restructuring and infrastructure/project finance. Craig specializes in advising middle market technology clients on mergers, acquisitions, divestitures and financing. Craig has a Master of Business Administration from the DeGroote School of Business at McMaster University and a Bachelor of Applied Science in Engineering from Queen s University. PwC 70 *PricewaterhouseCoopers Corporate Finance LLC is owned by PricewaterhouseCoopers LLP, a Delaware limited liability partnership and a member firm of PricewaterhouseCoopers International Limited. Each member firm of PricewaterhouseCoopers International Limited is a separate legal entity. PricewaterhouseCoopers Corporate Finance LLC is a member of FINRA and SIPC and is not engaged in the practice of public accountancy.

71 Impact of doing business in the US on deals (M&A, IPO, JV) PwC 71

72 Impact of cross-border sales on deals Does expanding your business into the US impact a potential exit? How Absolutely. does expanding 100%. Every your time. business into the US impact a potential exit? Quantitatively: - Higher valuations PwC 72 - Valuations are impacted by the size of the business at exit, competition for your deal, investor knowledge and analyst coverage. Qualitatively: - Exposure to potential acquirers and/or investors - Building relationships with potential buyers months or years in advance of a transaction. - Reach the size to attract attention.

73 Valuation The impact of deal size on price premium Across all verticals and sectors within software, software services and hardware, deal size significantly impacted valuations. In the over 500+ deals we ve tracked during the past 12 months with published deal metrics (normalized for pre-revenue and blockbuster deals), we observed a significant premium for deals above $50 million: PwC 73 Deals under $50 million had an average Enterprise Value to Revenue multiple of nearly 2.0x; while Deals $50 million and above had an average multiple of nearly 3.5x and the median EV/EBITDA multiple was 4 turns higher. M&A deals involving a public company exhibited a similar trend whereby public targets, on average, were valued at 1.5 turns higher than their private counterparts.

74 Exposure to acquirers and investors The impact of cross-border sales on getting a deal done M&A is still the preeminent exit strategy for Canadian technology business owners/investor over 80% of respondents from the PwC 2010 Technology CEO survey agreed (up from 73% in 2009). In addition to the strategic reason for expanding into the US, or internationally, doing so can improve the prospects of a successful exit by providing: PwC 74 Exposure to new customers or partners who are the most likely potential acquirers; and Growth opportunities which can position a business above the minimum thresholds for some serial acquirers or PEs. The prospect of US customers also impacts non-monetary deal consideration during a buyer s/investor s due diligence and their perception of risk from customer concentration or exposure to potential tax liabilities.

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