Presented jointly by:

  May 11-12, 2016


The registration desk will open at 7:30 am on Wednesday, May 11, and will remain open for the duration of the event. The symposium will take place in room 701 (Level 700 )of the South Building at the Metro Toronto Convention Centre | 222 Bremner Blvd.

Pre-registered delegates of the event may access the materials here:


Special thank you to our sponsors!

Wednesday, May 11,  2016
7:30 am -
8:30 am 
Registration & Breakfast
8:30 am -
9:30 am
Key Events in the History of the Income Tax Act – Wars, Depression/Recessions, and Prosperity


  • Events that shaped the Act
  • Impact of shifts in social policy and societal values
  • Milestones in the life of the Act: 1917, 1948
  • Carter Commission

Panel Leaders:
Associate Professor Kim Brooks, Schulich School of Law, Dalhousie University, Halifax
Neil Brooks, Professor Emeritus, Osgoode Hall Law School, York University, Toronto

Associate Professor Colin Campbell, Faculty of Law, Western University, London
Robert Raizenne, Osler, Hoskin & Harcourt LLP, Montréal
Professor Shirley Tillotson, Department of History, Dalhousie University, Halifax
Daryl Boychuk, Canada Revenue Agency, Ottawa

9:30 am -
10:30 am
The Government’s Tax Policy Decision Making Process Themes


  • The Budget making process
  • The tension between good public policy and politics
  • The relation of tax policy to fiscal policy and other key policy areas
  • The challenges of translating policy into legislation including the challenges of balancing complexity and fairness

Panel Leader:
Stephen Richardson, Executive Fellow, School of Public Policy, University of Calgary

Elly Alboim, Earnscliffe Strategy Group, Ottawa
Len Farber, Norton Rose Fulbright Canada LLP,  Ottawa
Michael Horgan, Bennett Jones LLP, Ottawa

10:30am -
10:45 am
Refreshment Break
10:45 am -
11:30 am
Perspectives of a Former Finance Minister: The Honourable Michael H. Wilson, Chancellor of the University of Toronto and former Minister of Finance

Robert Couzin, Toronto

11:30 am -
12:30 pm

The Income Tax Act as “Accessory” -- What Is It “About”?


  • Origin of ITA’s reliance on general law for operation
  • Reliance on general law for technical tax architecture (e.g.,meaning of “disposition” and “gift”
  • Reliance on general law for delivery of tax expenditures (e.g., “charity” and “charitable purposes”)
  • How mutable general law influences the tax system (e.g., classification of business entities and financial instruments)
  • Appropriateness of reliance on the private law

Panel leader:

Professor Tim Edgar, Osgoode Hall Law School, York University, Toronto
Brian Carr, KPMG Law LLP, Toronto


Matias Milet, Osler, Hoskin & Harcourt LLP, Toronto
Professor Martha O’Brien, Faculty of Law, University of Victoria, Victoria
Professor Adam Parachin,  Faculty of Law, Western University, London

Ian Crosbie, Davies Ward Phillips & Vineberg LLP, Toronto

12:30 pm -
1:30 pm

1:30 pm -
2:45 pm
Personal Income Tax: Tax Units and the Comprehensive Tax Base


  • 100 year evolution of the personal income tax
  • Tax unit and treatment of families
  • Consumption vs. Income aspects of the tax base  
  • Where to from here?     

Panel leader:
Professor Kevin Milligan, Vancouver School of Economics, University of British Columbia, Vancouver


Professor J. Rhys Kesselman, School of Public Policy, Simon Fraser University, Vancouver
Professor Kathleen Lahey, Faculty of Law, Queen's University, Kingston

Professor James Davies, Department of Economics, The University of Western Ontario, London
Associate Professor Tammy Schirle, Department of Economics, Wilfrid Laurier University, Waterloo

2:45 pm -
3:00 pm
Refreshment Break
3:00 pm -
4:30 pm
Corporate Income Tax: Shareholders and “Corporations” as A Tax and Taxable Unit


  • Grading the corporate income tax’s performance in the 100 years  
  • Separate entity v. integrated economic unit
  • Evolving economic, business and legal context   
  • Selected themes (tax rates, interaction with retirement saving schemes, interaction with foreign systems)
  • Do we (still) have –should we still have -- a corporate income tax?

Panel leader:

Scott Wilkie, Blake, Cassels & Graydon LLP, Toronto


Robin Boadway, O.C., F.R.S.C., Professor Emeritus, Economics Department, Queen's University, Kingston
Jim Wilson, PwC Law LLP, Toronto

Siobhan Monaghan, KPMG Law LLP, Toronto

4:30 pm  -
7:30 pm
Cocktail Reception
Thursday, May 12,  2016
7:30 am -
8:30 am
Registration & Breakfast
8:30 am -
9:45 am
International Taxation: Canada’s Place in the World


  • Defining the Canadian share of international income over 100 years
  • Role of ITA in serving Canada’s national interest in a changing global context
  • Key “fiscal theorems” underlying the ITA’s international rules
  • Interaction between the ITA and tax treaties
  • Milestones in Canadian treaty policy and inbound/outbound regimes
  • A Checkup: How “healthy” is the ITA’s international dimension?
  • Will the past predict the future?

Panel leader:
Professor Jinyan Li,  Osgoode Hall Law School, York University, Toronto


Brian J.  Arnold, Canadian Tax Foundation, London
Angelo Nikolakakis, EY Law LLP, Montréal
Scott  Wilkie, Blake, Cassels & Graydon LLP, Toronto

Shawn D. Porter, Deloitte LLP, Toronto
Brian Mustard CPA, CA, BCE Inc., Montreal

9:45 am -
10:45 am
Tax Expenditures: Spending the Fiscal Currency


  • Role of tax expenditures in Canadian tax policy
  • Funding collective consumption fairly through taxation
  • Check-up: “weight-gain” of the ITA due to tax expenditure provisions
  • Empirical review of “take-up” rate of selected tax expenditure programs
  • Resource Expenditures and flow-through shares
  • Tax expenditure review and management

Panel leader:

Professor Lisa Philipps, Osgoode Hall Law School, York University, Toronto


Neil Brooks, Professor Emeritus, Osgoode Hall Law School, York University, Toronto
Associate Professor Thaddeus Hwong, York University, Toronto
Associate Professor Alan Macnaughton, University of Waterloo
Associate Professor Lindsay Tedds, University of Victoria, Victoria
John Lester, Executive Fellow, School of Public Policy, University of Calgary

Paul Berg-Dick, MEKA and Associates, Ottawa

10:45 am -
11:00 am
Refreshment Break
11:00 am -
12:45 pm
Administering the Tax: Making It All Work


  • Evolution of the administration of the ITA over time
  • Pattern of taxpayer behaviour
  • Changing role of courts
  • The role of politics in administration of the Act

Panel leader: 
Wayne Adams, Canadian Tax Foundation, Ottawa


William Baker, Commissioner, Canada Revenue Agency - (retired)
Warren Mitchell Q.C., Thorsteinssons LLP, Vancouver
David Penney, CPA, CA, General Director – Taxes, General Motors of Canada - (retired)
Hon. Marshall Rothstein, Q.C., Associate Counsel, Hunter Litigation Chambers, Vancouver
Hon. Karen Sharlow, Counsel, Taxation, Osler, Hoskin & Harcourt LLP, Vancouver

Justin Kutyan, KPMG Law LLP, Toronto

12:45 pm -
1:45 pm
1:45 pm -
3:30 pm
Looking Back to Look Ahead — Critical Themes, Milestones, and Future Directions

During the closing session, the panel will comment on various topics addressed throughout the symposium and will discuss some of the issues raised in the following questions.
  • What does the evolution of the Income Tax Act over the past 99 years tell us about where it might be headed in the future?
  • Will the income tax continue to have a significant role in the future fiscal framework of Canada – do we have the right mix between the various sources of tax revenue – personal, corporate, consumption, environmental and other taxes?
  • Based on your own views and the views expressed in the papers presented and in the panel discussions over the past two days, what do you see as the key steps in the evolution of the income tax from where it is today to where it should go in the future?        
Panel leader:
Larry Chapman, FCPA, FCA, Executive Director and CEO, Canadian Tax Foundation, Toronto


Richard M. Bird,  Professor Emeritus, University of Toronto
Neil Brooks, Professor Emeritus, Osgoode Hall Law School, York University, Toronto
Robert Couzin, Toronto
Kevin Dancey, FCPA, FCA, CPA Canada, Toronto
Jack Mintz, President's Fellow, School of Public Policy, University of Calgary

Fees & Registration  

Registrations are now closed for this event

Individual Registration 


Regular Registration 

Substitution & Cancellation

If you are unable to attend the conference, registration may be transferred to another individual. Please submit the name of the substituted delegate to up to three business days prior to the start of the conference. After that, the substitution will be accepted only at the conference site. Please note: if you transfer your registration to another person, additional charges may apply, depending on the transferee’s membership status. We regret that we cannot issue refunds for notices of cancellation for this event.

Personal Information Consent:

Information collected as part of your registration will be used and disclosed by the Foundation for the purposes of administering the conference. In addition, a delegate list containing names, companies, and cities is produced, and is made available to those who may be involved with the Foundation who may wish to contact delegates regarding their activities. By emailing us at, you declare that you do not wish your name and contact information to be included in the delegate list and disclosed. For more information on our privacy practices, see our privacy policy here.

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5/27/2018 7:32:15 AM