British Columbia Tax Conference

Keeping Tax Practitioners Informed

Monday and Tuesday, September 23-24, 2013

Vancouver Convention Centre
1055 Canada Place


Online registration is now closed.
Those wishing to register may do so onsite.


Printable Program at a Glance - PDF


This program is eligible for up to 12.75 Substantive Hours by the British Columbia Law Society.

Conference App


Monday, September 23, 2013
7:00 am  Registration 
7:00 am -
8:00 am


Sponsored by


8:00 am -
8:15 am
Opening Remarks 
8:15 am -
9:10 am

Current Issues Forum 

The 2013 Federal and BC Budgets contained a treasure trove of substantive tax changes. This session will review the more significant budget proposals, other recent legislative changes, and federal and provincial administrative developments that have an impact on individuals and small and medium-sized private businesses.

Don Furney, PricewaterhouseCoopers LLP, Vancouver
Frank Quo Vadis, Koffman Kalef LLP, Vancouver            

9:10 am -
10:05 am

Current Cases

A review of recent decisions from the Tax Court, the Federal Court of Appeal, and the Supreme Court that affect owner-managed businesses and private companies. 

 Allison Blackler, Couzin Taylor LLP, Vancouver
 Joel Nitikman, Dentons Canada LLP, Vancouver                        
10:05 am -
10:20 am
10:20 am -
10:40 am
Refreshment break

Sponsored by

10:40 am -
11:25 am

Update on Corporate Loss Utilization Rules and the Impact of Proposed Anti-Avoidance Rules in the Budget
Budget 2013 announced that a system of corporate group taxation will not be implemented.  This session will review and update other techniques for utilization of group tax attributes, including:            

  • the impact of the 2013 federal budget
  • administrative developments
  • effective loss utilization techniques
  • limitations and technical issues
  • best practices when applying for an advance income tax ruling (including guidance from Rulings)
 Soraya Jamal, Blake, Cassels & Graydon LLP, Vancouver
11:25 am -
12:00 pm
Interprovincial Planning After Husky & Safeway - Is It Abusive to Go Province Shopping?

With the 2013 provincial budgets, rate differences will require an analysis of income-shifting options. This session will examine ways to optimize provincial tax exposure.
Tim Clarke, Bull, Housser & Tupper LLP, Vancouver
Kim G.C. Moody, CA, TEP, Moodys Tax Advisors, Calgary
12:00 pm -
12:15 pm
12:15 pm -
1:45 pm


Sponsored by

1:45 pm -
2:30 pm

BC's Transition from HST to PST - Surprises and Traps

The reintroduction of a provincial sales tax in BC and the repeal of the harmonized sales tax may have made Bill Vander Zalm happy, but many individuals and businesses are encountering surprises and falling into traps that were not expected. This session will review the significant changes and transitional issues faced by taxpayers arising from some of the new features of the old tax.            

Terry Barnett, Thorsteinssons LLP, Toronto & Vancouver
Janice Roper, CA, Deloitte LLP, Vancouver
2:30 pm - 
3:05 pm

Canada-Hong Kong Income Tax Agreement      

The fact that Canada and Hong Kong have negotiated a tax treaty might be seen as surprising. However, it is consistent with Canada's desire to gain greater access to information that can be obtained through the exchange-of-information provisions that are included in treaties.  This session will examine the tax-planning opportunities that arise from this new treaty and the possible consequences of more robust information exchanges between the two governments.

Joyce Lee, Deloitte Tax Law LLP, Vancouver
James W. Radelet, Radelet & Company, Vancouver
3:05 pm -
3:15 pm
3:15 pm -
3:35 pm

Refreshment break

Sponsored by

3:35 pm -
4:20 pm 

Family Law Changes and the Implications for Trust and Estate Tax Planning 

BC's Family Law Act is now fully in effect.  This topic will discuss the impact on family and estate planning. While the panel will not focus on changes in other provinces, lessons learned in BC will be helpful to practitioners and their clients across Canada. 

Paul Daykin, QC, Aaron Gordon Daykin Nordlinger LLP, Vancouver
Carmen Thériault, QC, Bull, Housser & Tupper LLP, Vancouver            
4:20 pm - 
5:05 pm
Hybrid Assets Share Planning when Selling Private Enterprises

In tax planning it is often not easy to have your cake and eat it too. Often one taxpayer has to sacrifice so another can enjoy a benefit. The session will examine whether, through proper structuring of the disposition of shares of a company as a hybrid sale of assets and shares, the purchaser and the vendor can both have a cake and eat it.         
Dave Rickards, Grant Thornton LLP, Vancouver
5:05 pm -
5:15 pm
5:15 pm -
7:15 pm

Evening Reception


Tuesday, September 24, 2013
7:30 am
Registration Desk Opens
7:30 am -
8:30 am  


Hosted by

8:30 am -
9:15 am

Strategies for Dealing Effectively and Efficiently with CRA Audit Issues and Challenges

Disagreements frequently arise with CRA Audit concerning documentation, findings of fact, interpretation of the Income Tax Act, corporate, partnership or trust laws, and even the timing of income or expense reporting.  This panel will discuss ways to resolve these disputes with Audit or Appeals, in an effort to minimize the number of disputes that head toward the Tax Court.  

John Marquis, Chief of Appeals, Canada Revenue Agency, Vancouver
Joanne Ralla, Canada Revenue Agency, Surrey
Alexander G. (Sandy) Stedman, CA, Schibli Stedman King, Victoria
Max Weder, Davis LLP, Vancouver
9:15 am -
10:00 am

Owner-Manager Remuneration Update - Including Employee Incorporated PSB Rules and Integration 

This session will provide an update on the integration of the ever-changing tax rates as they are applicable to individuals, corporations, and trusts in BC.  The synthesis of these rates is then applied to the concept of integration in order to see how these tax rates can affect taxpayers’ decisions on how and through which kind of vehicle to earn income.

Don Carson, CPA, CA, MNP LLP, Markham
Amanjit Lidder, CA, MNP LLP, Surrey
10:00 am -
10:15 am
10:15 am -
10:35 am

Refreshment break

Sponsored By

10:35 am -
11:25 am
Canada-US Cross-Border Tax Issues for Individuals 

Traditional Canadian estate planning can be ineffective and punitive for participants if they are currently or will be in the future US citizens or US permanent residents. This session will examine the issues that will be faced if a US taxpayer is involved in a traditional Canadian estate plan and steps that can be taken to avoid some of the onerous tax consequences and compliance burdens that arise.

Benita Loughlin, CA, KPMG LLP, Vancouver
Elaine Reynolds, Legacy Tax + Trust Lawyers, Vancouver
11:25 am -
12:00 pm
Revisiting the Attribution Rules

The session will review the application of subsection 75(2) in light of the decision in the Sommerer case, recent budget changes, and the CRA’s evolving interpretation of the subsection. In addition, taxpayers and their advisors are finding that the interaction of subsection 75(2) with the trust property rollover rules in subsections 107(4) and 107(4.1) are proving too problematic in some circumstances. This session will review the interaction of these provisions and the steps that can be taken to achieve their intended application.
As a result of very low interest rates, the use of prescribed rate loans to split income is becoming very attractive. This session will also review the more significant attribution rules found within the Income Tax Act and discuss how to avoid their application and certain other issues relevant to these rules. Recent cases that have considered the application of GAAR to planning in connection with application of the attribution rules will also be considered. 

David Thompson, Thorsteinssons LLP, Vancouver
12:00 pm -
12:15 pm
12:15 pm -

Sponsored by

1:30 pm -
2:05 pm

Pre- and Post-Mortem Planning for Charitable Giving

High-wealth individuals often make their largest charitable donations at or near their death and directly or through their will and estate plans.  This session will discuss ways to ensure that tax credits are maximized and not denied.

    Blake Bromley, Benefic Group Inc., Vancouver

2:05 pm - 
2:40 pm

Surplus Stripping - Defining the Acceptable Boundaries

Discussion of the views of practitioners, the CRA, Finance, and the courts on the extraction of surplus from corporations.  Given the recent direction of the Federal Court of Appeal in MacDonald, are there still planning opportunities?

Jacqueline Fehr, KPMG Law LLP, Vancouver
Mark Meredith, Moskowitz & Meredith LLP, Vancouver            
2:40 pm -
2:55 pm
2:55 pm -
3:15 pm
Refreshment break
3:15 pm -
4:15 pm

Defining the Boundaries of Acceptable Tax Planning in the Face of Increased Public Scrutiny
Recent coverage in the media has focused on the morality of the planning activities of certain multinational enterprises. The OECD has entered the debate with its discussion paper on Base Erosion and Profit Shifting.  Even though the attention of the media and government seems to be on large business, it is clear that the planning activities of high net worth individuals and private business are of great interest to the tax authorities. This session will discuss the acceptable limits of tax planning in the context of high net worth individuals and private business. Panelists will debate and provide their personal perspectives on the acceptable boundaries, and retired CRA personnel will outline hot buttons for tax authorities.

Moderator: Larry Chapman, FCPA, FCA, Canadian Tax Foundation
Tim Duholke, FCA, Davis LLP, Vancouver
Phil Jolie, Ottawa
Deen Olsen, Department of Justice, Ottawa            
4:15 pm -
4:30 pm
4:30 pm Adjournment
  Program subject to change. Please check back frequently for the most up-to-date version.

Other Sponsors

Onsite Program:
Sponsored by

Delegate Bags:
Sponsored by

Conference Binder:
Sponsored by

Delegate Pens:
Sponsored by


UBC Law - LL.M. in Taxation

Program Committee

Darren Bank, CA
Grant Thornton LLP
David Baxter
Thorsteinssons LLP
Tim Clarke*
Bull, Housser & Tupper LLP
Michael Coburn
Fasken Martineau DuMoulin LLP
Ian Heine, CA
PricewaterhouseCoopers LLP
Amanjit Lidder, CA
Bill Macaulay
Smythe Ratcliffe LLP
Lori Mathison
Dentons Canada LLP
Luke Mlynarczyk
Legacy Tax + Trust Lawyers
John Ormiston, CA
Deloitte LLP
J. Andre Rachert
Dwyer Tax Lawyers
Linda Richkum
Bruce Sinclair, CA
Blake, Cassels & Graydon LLP 

*Governor, Canadian Tax Foundation

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   Member Non-member
Regular  $945 $1295
Government  $745  $895
Young Practitioner  $645 $795
Full-time Academic  $195 $195
Full-time Student  $100 $100 
Conference Materials**  
Conference Binder  $50.00 
Electronic   $0.00
** Important notes:

Conference Materials (papers and powerpoint presentations) will be posted on the CTF web site and Conference App prior to the conference. The conference registration fee includes electronic access to these materials; the registration fee does not include a printed copy of the materials.

If you would like to receive a Conference Binder, please select this option when registering; you will be charged an additional $50.00 to cover the cost of the binder.

Sharing a single registration between two or more individuals is not permitted. Access to conference meetings, meal functions, and related events will be limited to registrants wearing valid name badges.

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Hotel Accommodation

Out-of-town registrants should make their own hotel arrangements directly with the Fairmont Waterfront Hotel

Please note: our room block at this hotel is now sold out.

Fairmont Waterfront Hotel
900 Canada Place Way, Vancouver, BC
V6C 3L5

 Reservations Direct Line:  1.866.540.4509

 International Toll-Free Number:  1.800.257.7544

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If you are unable to attend the conference, registration may be transferred to one other individual. Please submit the name of the substituted delegate to Robyn Corrigan at up to three business days prior to the start of the conference. After that, the substitution will be accepted only at the conference site. If substitution is not an option, written notice of cancellation will be accepted by the Conference Department Monday, September 16, 2013. Individuals who cancel their registration prior to this deadline will receive a refund, less a $100 administration fee, at the conclusion of the conference. We regret that we cannot issue refunds for notices of cancellation received after this deadline.

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8/20/2017 2:06:24 AM