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Live Webcast:
The Foundation is pleased to bring you its first live webcast of the 2017 British Columbia conference. Individual and group rates are both available. Click here for details.

A Taste of Tax: Introducing a special dine-around event. Click here for more details

Program | September, 18, 2017
7:00 am 
Registration and Breakfast

8:00 am
Opening Remarks
Heather L. Evans, Executive Director & CEO, Canadian Tax Foundation

8:15 am -
9:15 am
Current Cases

A review of recent decisions that affect owner-managed businesses and private companies.

Soraya Jamal, Blake, Cassels & Graydon LLP, Vancouver
Scott Murtha, PwC Law LLP, Vancouver

9:15 am -
10:15 am
A Practical Approach to Calculating Safe Income - Case Study

Given the recent amendments to subsection 55(2) of the Act, safe income might be a taxpayer’s only line of defense to prevent the re-characterization of a tax free inter-corporate dividend into a taxable capital gain. Because of this increased reliance on safe income, it is important for professionals to understand the intricacies involved in the determination of safe income for the shareholders’ of a corporation.  While many professionals understand the determination of “safe income” in theory, complications arise when this theory is applied to the real world determination of safe income for an actual taxpayer.

The presentation will cover the following topics:

1. The concept of what safe income is;
2. The distinction between safe income and safe income on hand;
3. Key issues to consider in calculating safe income, including the relevant case law and CRA guidance ;
4. How safe income is allocated between different shareholders and multiple classes of shares;
5. The impact of typical corporate reorganizations on the determination of safe income and allocation of safe income to shareholders; and
6. Practical alternatives to the payment of dividends where sufficient safe income does not exist.

Paul Cormack
, Ernst & Young LLP , Vancouver

10:15 am -
10:25 am
10:25 am -
10:45 am

10:45 am -
11:45 am
Pick Your Poison: The Planning Pros and Cons of Avoiding an Estate

Andrea Frisby, Legacy Tax + Trust Lawyers, Vancouver
Kate Marples, Legacy Tax + Trust Lawyers, Vancouver

11:45 am -
12:25 pm

Private Corporations - Budget 2017

Following on the heels of the 2016 review of tax expenditures, the Department of Finance announced in Budget 2017, that it will release a comprehensive paper in the coming months on the taxation of private corporations including some policy responses to concerns set out therein.  Areas of concern included income splitting with family members, deferral of full taxation of investment returns, and potential conversion of regular income into capital gains.  Also of note was the statement that Finance would also examine whether the current system produces adverse tax results on transactions with family members which would not otherwise occur with unrelated third parties, which many interpret as signalling a relook at Section 84.1.  This session will cover both the areas of concern, Finance’s intended policy response, and share thoughts on strategies to minimize unintended adverse impacts on clients. 

David Badalucco, CPA, CA, Grant Thornton LLP, Vancouver
James Radelet, Radelet & Company LLP, Vancouver

12:25 pm - 
12:35 pm 
12:35 pm - 
2:20 pm

Canada and America, Trudeau and Trump: An Update
Guest Speaker:
James Moore, Senior Business Advisor, Dentons Canada LLP, Vancouver

2:20 pm -
3:10 pm
US Tax Update

The presentation will cover the following topics:

1. Candian companies carrying on business in the US
2. Trump agenda
3. US taxpayers in Canada - disclosure, compliance, renunciation
4. Real estate developers expanding into the US

Max Reed, SKL Tax, Vancouver

3:10 pm - 
3:50 pm
 Equitable Remedies and Fixing “Corporate Mistakes” under the BCBCA

Kimberley Cook,
Thorsteinssons LLP, Vancouver
The Hon. Karen Sharlow,
Osler, Hoskin & Harcourt LLP, Vancouver
3:50 pm - 
4:00 pm 
4:00 pm - 
4:20 pm  

4:20 pm - 
5:20 pm  
Principal Residence Planning

The presentation will cover the following topics:

1. Background of “old rules”
2. October 2016 amendments
3. Planning for individuals
4. Planning for trusts
5. House “flipping”
6. B.C. foreign buyer’s property transfer tax (and as of April 2017, Ontario has one too)
7. Vancouver’s “Vacancy Tax” for empty properties

Noah Sarna, Thorsteinssons LLP, Vancouver
Hugh Woolley, CPA, CA, Lewis & Company, CAs, Vancouver

5:20 pm - 
5:30 pm 
5:30 pm - 
7:30 pm  

Program | Tuesday, September 19, 2017
7:15 am 
Registration and Breakfast

8:15 am -
9:15 am

Current Issues, including Owner-Manager Update

A review of recent legislative and administrative developments in federal and provincial tax law, including a review of federal and provincial budgets for 2017.

Lisa Heddema, Smetheram & Company, Vancouver
Other speaker: TBA

9:15 am -
10:15 am
CRA Technology Strategy, CRA's Reach for Information & Electronic Records

In Canada, the majority of individuals and businesses file their tax returns and pay what they owe, in full and on time. However, there are some who operate outside of the legislative framework to avoid or evade the paying the taxes they owe. Finding these people and fighting the avoidance and evasion of tax is one of the Canada Revenue Agency’s top priorities.

The CRA uses technology to find and address tax evasion. Advanced data analysis techniques allow the Agency to look at industry trends, people’s behaviour, and predict the industry sectors in which tax evasion is more likely or taxpayers are more likely to be non-compliant.

This panel discussion will explore:

1. CRA’s use of technology to identify high risk taxpayers for evasion
2. Sources of data that provide insights into the underground economy such as:
    a. Cheque cashing companies;
    b. Information matching from public records (i.e. real property registry)
    c. Analysis of supplier information (constructing contracts reporting)
    d. Financial institutions and international payments
    e. Exchange of information agreements
    f. Social media
3. Taxpayers expectations of privacy
4. Electronic records and reach for information
5. The future of tax compliance
6. The future of tax litigation

MODERATOR: David Miller, Deloitte LLP, Vancouver
Tom Boddez,
Thorsteinssons LLP, Vancouver
Gina Jelmini, Director General of the Offshore and Aggressive Tax Planning Directorate, Canada Revenue Agency, Ottawa
Dagmar Zanic, CPA, CA, Manning Elliott LLP, Vancouver

10:15 am -
10:25 am
10:25 am -
10:45 am

10:45 am -
11:35 am
Planning in Partnerships & Joint Ventures

1. PST issues
2. Pros & cons of partnerships for real estate developers
3. Partnerships: general vs limited v LLP

Roque Hsieh, CPA, CA, KPMG LLP, Vancouver
Tony Tse, CPA, CA, KPMG LLP, Vancouver

11:35 am -
12:15 pm

 Ballparks Rarely Work:  A Primer on Valuations 

A tax plan for a private company may give rise to a number of valuation issues.  For example, property may be transferred between non-arm’s length persons or a reorganization of capital could precede an estate freeze or a new investor. A proper valuation could avoid an additional tax liability, the conferral of benefits or the attribution rules.  Valuation is not restricted t tax -- parties to litigation may call into question the valuation of shares either at a time of a reorganization or as a result of future conduct. The CRA may also have a view – often with the benefit of hindsight. This session will address some of the factors considered by  a valuator in the context of private companies transactions.  Topics will include confirming the relevant time for establishing a value for purposes of the Income Tax Act,  the attributes of preferred shares that will affect value, the relevance of ancillary agreements such as a shareholders’ agreement, the effect of a controlling position or a minority position on value,  allocation of value among various classes of shares, the value of skinny shares, fair market value of shares at the time of the grant of a stock option, the value of fractional interests in real property and the value of a discretionary interest in a trust.

Cathie Brayley,
Clark Wilson LLP, Vancouver
Jeffrey Harder, Deloitte LLP, Vancouver

12:15 pm - 
12:25 pm 
12:25 pm - 
1:30 pm

1:30 pm -
2:10 pm
Discussion of the QSBC Rules

Ian Worland, Legacy Tax + Trust Lawyers, Vancouver
Other speaker: TBA

2:10 pm -
2:55 pm
Stock Options, with a focus on Start-ups

This discussion will include:

1. Use of stock-based compensation to attract talent
2. Focus on start-up companies, notably in tech sector
3. Employees versus independent contractors
4. Statutory requirements for stock option deduction under 110(1)(d) – founders, key employees
5. Which entity should issue options
6. Cross-border considerations for US operations and US employees – differences in US rules
7. Alternative to options such as phantom stock
8. Planning on exit/liquidity event (eg. should employees be parties to share purchase agreement and alternative methods to cash out employees)

Michael Coburn,
Fasken Martineau DuMoulin LLP, Vancouver
2:55 pm - 
3:05 pm 
3:05 pm - 
3:25 pm  

3:25 pm - 
4:25 pm  
Discretionary Trust Planning & Compliance

Practitioners commonly use discretionary trusts (“Trusts”) for purposes of implementing/maintaining tax planning strategies and may from time to time overlook dotting the i’s and crossing the t’s. With Canada Revenue Agency’s (“CRA”) current audit activity of Trusts, this session will review relevant matters in respect of Trust planning and related compliance from the perspectives of a practitioner and a lawyer and include a discussion of, among other things, the following:

1. Trustee’s obligations, fiduciary duties, legal principles and knowing the ground rules;
2. Best practices in respect of documentation such as Trustee’s minutes/resolutions, financial statements, allocation of income and proof of payment (i.e. meeting the meaning of paid or payable);
3. Allocation of capital gains and related capital gains deduction - qualified small business corporation shares;
4. Residency of Trusts including inter-provincial;
5. Proper settlement of Trusts and the manner in which the Trust acquires shares in a corporation;
6. What’s the end game – 21 year rule; and
7. Extension of CRA audit to related reorganizations and transactions.

Richard Weiland, Clark Wilson LLP, Vancouver
Kevin Wong, CPA, CA, MNP LLP, Vancouver

4:25 pm -
4:35 pm

4:35 pm
  Program is subject to change. Please check back frequently for the most up-to-date version.

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7/24/2017 10:44:43 PM