Online registrations are now closed. Please contact us at for any inquiries.
The registration desk will open at 7:15am on Monday morning and will remain open for the duration of the conference. Please check in at the registration desk, located in the Plaza ABC foyer of the hotel (655 Dixon Rd. Toronto) 
Pre-registered delegates can access materials here

Monday, October 23, 2017
7:15 am -
8:15 am
Registration & Breakfast
8:15 am -
8:30 am 
Opening Remarks

Heather L. Evans
, Executive Director and Chief Executive Officer, Canadian Tax Foundation

Moderator:  Alex Ghani, CPA, CA, CPA Solutions LLP
8:30 am -
9:20 am
Private Corporation Taxation: A review of the Department of Finance proposals 

On July 18, 2017, the Department of Finance released its consultation policy paper on the taxation of private corporations first announced in Budget 2017, along with proposed legislation on some of the topics addressed. The proposals will fundamentally change long-standing tax policy and will have far-reaching implications for all private enterprises and their stakeholders.
- Proposed “tax on split income” rules;
- Proposed lifetime capital gains exemption restrictions;
- Transitional rules for lifetime capital gains exemption; 
- Amendments to section 84.1 and proposed section 246.1;
- Impact on inter-vivos trusts and post-mortem planning; and
- Passive investment proposals.

Kyle Lamothe, Thorsteinssons LLP, Toronto
Brandon Wiener, Thorsteinssons LLP, Toronto

9:20 am -
10:10 am
Current Cases

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

Colin Chambers, CPA, CA, MNP LLP, Toronto
Ryan Morris, WeirFoulds LLP, Toronto

10:10 am -
10:20 am
10:20 am -
10:40 am
Moderator:  L. David Fox, Cummings Cooper Schusheim Berliner LLP
10:40 am -
11:20 am
Current Issues

A review of the 2017 technical interpretations issued by CRA, new Folios, the draft Circular on the Voluntary Disclosure process and recently tabled legislation.  

Jesse Brodlieb,
Dentons Canada LLP, Toronto
Larry Nevsky,
Dentons Canada LLP, Toronto

11:20 am -
12:00 pm
Selected Issues in Purchase and Sale Transactions

This session will discuss the following:

  1. Tax clauses in purchase and sale agreements
  2. Restrictive Covenants
  3. Indemnification
  4. Earn-outs

Andrew Stirling, McMillan LLP, Toronto

12:00 pm -
12:10 pm
12:10 pm -
2:10 pm
Artificial Intelligence
Guest Speaker:
Professor Benjamin Alarie
University of Toronto Faculty of Law
Moderator: Larry Chapman, FCPA, FCA, Toronto
2:10 pm -
2:50 pm

256(5.1) - De Facto Control - A Return to the Past

The concept of de facto control under subsection 256(5.1) of the Income Tax Act continues to be important as it relates to varicose aspects of the Act such as CCPC status. The 2017 Federal Budget and recent cases have affected the meaning of de facto control. This session will explore the current meaning of de facto control and its implications for tax planning,

Phil Friedlan, Friedlan Law, Richmond Hill

2:50 pm -
3:30 pm

The New ECP Rules and Changes to SBD - An In-Depth Review

This session will focus on the practical aspects of how a practitioner should implement two of the biggest changes in the Income Tax Act (“the Act”) that impact private corporations.

ECP Rules:
This portion of the presentation will focus on the new Class 14.1 from the acquisition of the asset both pre and post 2017 to the ultimate disposition of the asset which was in existence both pre and post 2017. Furthermore, this portion of the presentation will discuss if there is anything new in respect to the transitional rules and the impact that these rules will have on hybrid transactions.

Small Business Deduction (“SBD”):
This portion of the presentation will focus on the practical aspects of the new SBD rules. These include:
a) How to identify SCI in your client groups
b) How to calculate Specified Corporate Income and the pitfalls that the practitioners will face with calculating this income;
c) The assignment provisions under 125(3.2) and 125(8) of the Act and how a practitioner can assign the business limit over from one company to another;
d) The back to back rules and how they work."

Jeanne Cheng,
CPA, CA, MNP LLP, Markham

3:30 pm -
3:40 pm
3:40 pm -
4:00 pm

Moderator: Martin Sorensen, Bennett Jones LLP
4:00 pm - 
4:45 pm
Effective Tax Planning for Estates with a focus on Estate Law & Family Law to Minimize Litigation

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 Ontario. 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 about how, and through which kind of vehicle, to earn income.  

Panel Moderator: Martin Sorensen, Bennett Jones LLP, Toronto
Clare Burns, WeirFoulds LLP, Toronto

4:45 pm -
4:55 pm
4:55 pm -
7:00 pm    

Networking Reception
Tuesday, October 24, 2017
7:30 am -
8:30 am
Registration & Breakfast
Moderator:  Heather L. Evans, Canadian Tax Foundation 
8:30 am -
9:20 am
New 55(2): A Purposeful Review of the Results to Date

Paul Carenza, Gowling WLG (Canada) LLP, Toronto
Silvia Jacinto, Crowe Soberman LLP, Toronto

9:20 am -
10:10 am
Advanced Topics for American Shareholders of Private Canadian Companies

Previous articles have addressed many of the routine transactions involving Americans in Canada and their corporations. This session will build on those by looking at:

  1.  Investing in United States property;
  2. Sale of Controlled Foreign Corporations;
  3. Distributions from CFCs, and
  4. Typical Canadian reorganizations (ITA s 85(1), 86, 87 and 88).  They are not always as tax free as you think.

Kevyn Nightingale, CPA, CA, MNP LLP, Toronto
Dean Smith, CPA, CA, Cadesky Tax, Toronto

10:10 am -
10:20 am
10:20 am -
10:40 am

Kevin Stienstra, CPA, CA, Grant Thornton LLP
10:40 am -
11:20 am
Practical Solutions and Planning Considerations in respect of Outbound International Tax Traps for the Owner-Manager

This session will include a discussion on the following:

  1. Perils of disregarded entities including US LLCs
  2. CCPC integration issues
  3. Surplus Implications

Andrew Morreale, Grant Thornton LLP, Toronto
Andrew Somerville, Grant Thornton LLP, Mississauga
11:20 am -
12:00 pm
Investing in Canadian Real Estate by Non-Residents

Canada continues to a desirable destination for investment by non-residents in real estate. This session will explore the different structuring options, pitfalls, and considerations when non-residents invest in income producing real estate in Canada.

Rita Trowbridge, CPA, CA, BDO Canada LLP, Toronto West
James Witty, CPA, CA, BDO Canada LLP, Toronto

12:00 pm - 
12:10 pm
12:10 pm -
1:10 pm

Moderator: Cheryl Bailey,CPA, CA, Ernst & Young LLP
1:10 pm - 
1:50 pm
The Preferred Share Rules and the Private Corporation

The preferred share rules in Parts VI.1 and IV.1 and certain prohibitions on dividend deductibility in s.112 are longstanding provisions of the legislation. Many of these provisions derive from amendments in the 1978-1987 Tax Reform era. While some might believe that these rules apply only to debt-like shares issued in the financial sector, the broadly worded rules can apply to private corporations too. The application of the rules can result in dividend deductibility issues and the imposition of Part IV.1 tax on the dividend payer corporation. This session will discuss a selection of potential traps including problems with the substantial interest exemption, and how seemingly garden-variety common shares might be characterized as taxable preferred shares.

Joan Jung, Minden Gross LLP, Toronto

1:50 pm -
2:30 pm
Qualified Investments

The presentation will provide a review of the requirements for different types investments to qualify for a RRSP or other registered plan, including public corporations, mortgage investment corporations, mutual fund trusts, mortgages and eligible corporations. The presentation will also discuss the taxes payable on “non-qualified investments” and “prohibited investments”  held by a registered plan. The session will be of interest to professionals advising their clients either on making an investment through a registered plan or on structuring businesses to accommodate investment by registered plans.

Joelle Kabouchi, Borden Ladner Gervais LLP, Toronto
Laura White, Borden Ladner Gervais LLP, Toronto

2:30 pm -
2:40 pm

2:40 pm -
3:00 pm

Moderator: Michael C. Morgan, Ross & McBride LLP
3:00 pm -
3:50 pm

Share Compensation and Other Ways to bring Employees into Ownership of a Business

With the increasing number of businesses that will be transitioned to new owners in the next decade, it is important to consider tax issues surrounding the succession of a business. This session will focus on tax issues involving exit strategies where the business is not being transitioned to a family member, with an emphasis on how to transfer ownership to employees. It will explore issues such as when Section 7 of the Act will apply, the use of employee Buyco’s, and other strategies that can be utilized.

Ed Heakes, Dale & Lessmann LLP, Toronto

3:50 pm - 
4:40 pm
Planning for Principal Residences

Includes a discussion of the new rules:

  1. Changes and how they affect planning of trusts;
  2. Foreign buyers tax

Jeffrey Paisley, Deloitte LLP, Calgary
Lorna Sinclair
, Deloitte LLP, Toronto

4:40 pm -
4:50 pm
4:50 pm Adjournment


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9/24/2018 11:06:05 PM