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Your company is looking to invest and operate in Morocco. Canada has no bilateral investment treaty (BIT) with Morocco, but the US does. The corporate tax rates in the US are much higher than the rates in Canada, particularly for a Canadian controlled private corporation (CCPC). Would you suggest that the company set up a US corporation in order to take advantage of the US BIT with Morocco and pay higher taxes, or set up in Canada, which has lower corporate tax rates, but no FIPA protection for the investment? (This question greatly simplifies the complexities of the tax issue, but for the sake of what we are trying to analyze in this question, let us accept that the Canadian corporate taxes are much lower)