May 29-30, 2017
The Westin Edmonton Hotel | 10135 100 St NW, Edmonton, AB T5J 0N7

Advance registrations are now closed for this event. Please contact for any questions.

The registration desk will open at 7:15 am on Monday, May 29 and remain open for the duration of the conference. Please check in at the registration desk, located on the ballroom level of the Westin Hotel.

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Renew your acquaintances, create new alliances with other tax professionals and government officials, and benefit from great networking opportunities.
Program | Monday, May 29, 2017
7:15 am 
Registration and Breakfast

8:15 am
Opening Remarks
Heather L. Evans, Executive Director & CEO, Canadian Tax Foundation

Darryl R. Antel, Moodys Gartner Tax Law LLP, Calgary
8:30 am -
9:25 am
Current Issues

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

Dustin Burbank, Ernst & Young LLP, Edmonton
Sandra Mah, DLA Piper (Canada) LLP, Calgary

9:25 am -
10:20 am
Recent Court Decisions

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

Michel Bourque
, KPMG Law LLP , Calgary
Trevor Thomson, CA, Deloitte LLP, Calgary

10:20 am -
10:30 am
10:30 am -
10:50 am

Deborah MacPherson, KPMG LLP, Calgary
10:50 am -
11:35 am
Cross-Border Issues for Private Companies

This presentation is intended as a primer for the practitioner who advises owner-managed enterprises that engage in cross-border transactions.  The speakers will focus on the essential topics of international tax such as residence, permanent establishment, carrying on business, working with Canada’s treaties, active and passive income earned by non-residents, disposition of taxable Canadian property, regulation 102 and 105 withholdings, branch tax, and foreign tax credits and deductions.

Shaira Nanji, KPMG Law LLP, Calgary
Wanda Rumball, KPMG Law LLP, Calgary

11:35 am -
12:20 pm
The Informal Procedure of the Tax Court of Canada:  An Introduction

With increased thresholds for Tax Court appeals eligible for the informal procedure and with the increased cost of litigation, accountants can expect more requests from clients to advise them or to appear as their agent with respect to such appeals. Learn what to expect, and how best to proceed, from a judge of the Tax Court of Canada, Crown counsel, and taxpayer’s counsel.  

The Hon. Justice Don R. Sommerfeldt,
Tax Court of Canada, Ottawa
Carman McNary, QC, Dentons Canada LLP, Edmonton

12:20 pm - 
12:30 pm 
12:30 pm - 
2:05 pm

Reflections on Tax Practice – Yesterday, Today and Tomorrow
Guest Speakers:
Thomas B. Devaney, FCPA, FCA
Video Tax News
  Gordon W. Flynn, QC, FCA
Felesky Flynn LLP
  Christopher Sprysak
University of Alberta

Dustin Mansfield, CPA, CA, BDO Canada LLP. Brandon
2:05 pm -
2:45 pm

 Partnership and Joint Venture Tax and Accounting for Common Transactions

  1. Differentiating between partnerships and joint ventures from legal, commercial, tax and accounting perspectives
  2. Accounting for common tax transactions and events involving partnerships and joint ventures including treatment of:
    •  Contributions of property (including roll-ins)
    • Purchases of interests
    • Wind-ups (including roll-outs)
    • Year-ends
    • GST and PST

Phoebe Elliot, CPA, CA, Kingston Ross Pasnak LLP, Edmonton
Jay Winters, Bennett Jones LLP, Calgary

2:45 pm -
3:25 pm
The GAAR Post-Copthorne: Where We’ve Come From, and Current Applications

This session will consider the post-Copthorne GAAR jurisprudence, with the intention of identifying emerging themes and allowing practitioners to make educated assessments of when the GAAR may or may not apply to contemplated future transactions.  In addition, the importance (or unimportance) of the “artificiality” of transactions or arrangements will be considered, and the GAAR assessment framework will be applied to some tax plans that are currently in the market in order to identify potential risks.

H. Michael Dolson, Felesky Flynn LLP, Edmonton
3:25 pm - 
3:35 pm 
3:35 pm - 
3:55 pm  

Hugh Neilson, Kingston Ross Pasnak LLP, Edmonton
3:55 pm - 
4:50 pm  
Tax Administration Panel

Lisa Anawati,
Deputy Assistant Commissioner, Canada Revenue Agency, Ottawa
Janet Laibida, Assistant Director, Income Tax Audit, Edmonton Tax Services Office
Hugh Neilson, FCPA, FCA, TEP, Kingston Ross Pasnak LLP, Edmonton
4:50 pm - 
5:00 pm 
5:00 pm - 
8:00 pm  

Program | Tuesday, May 30, 2017
7:30 am 
Registration and Breakfast

Timothy Kirby, Felesky Flynn LLP, Edmonton
8:30 am -
9:25 am

The New Section 55 - Practitioner Perspectives on Where We Go From Here

The technical working of new subsection 55(2) has been covered by various papers and presentations. This topic will build on (but not revisit) those technical aspects. The theme of the topic is practical tools and information for working with new subsection 55(2). Three areas will be discussed:

  1. Safe income on hand — how to calculate it
  2. Revised planning techniques in the new subsection 55(2) environment (e.g., purification structures, purposely triggering 55(2))
  3. A summary of the various CRA interpretations and positions in respect of new subsection 55(2) and related planning and transactions.

Kenneth Keung, CA, TEP, Moodys Gartner Tax Law LLP, Calgary
Anthony Strawson, Felesky Flynn LLP, Calgary

9:25 am -
10:20 am
ECP Regime Change &  Hybrid Transactions

This session will review the new regime for Class 14.1 intangible properties, including the transitional rules that effected the conversion of eligible capital properties into Class 14.1 properties. The goal of this session is to allow practitioners to confidently advise their clients when dealing with Class 14.1 assets, to identify the tax attributes of Class 14.1 assets both now and in the future, and to determine the tax consequences of future dispositions of Class 14.1 assets.

The relatively favourable tax results of a sale of eligible capital properties was an important consideration in Geransky-style hybrid transactions. This session will continue by considering the state of the art of hybrid transactions, and when hybrid transactions remain a viable alternative to straightforward share or asset sales. Finally, various issues relating to hybrid transactions will be identified, as will the best practices for addressing these issues.

Jeremy Comeau, Felesky Flynn LLP, Edmonton
Margaret Paproski, CPA, CMA, Felesky Flynn LLP, Edmonton

10:20 am -
10:30 am
10:30 am -
10:50 am

Garnet Matsuba, MLT Aikins LLP, Edmonton
10:50 am -
11:40 am
Why I Still Love and Use Trusts Despite the Disincentives That Tax Law Has Given Us

This session will provide a brief overview of the tax challenges and pitfalls affecting trusts, including rules related to GREs, the new principle-residence rules affecting trusts, the 21-year rule, and others, followed by a discussion of when and why trusts are still useful in family and estate law and practical ways of working around and through the tax challenges and pitfalls, including the best practices for winding up a trust or estate.

MaryAnne Loney, McLennan Ross LLP, Edmonton
Karen Platten, QC, McLennan Ross LLP, Edmonton

11:40 am -
12:20 pm

 Is Rectification Still a Remedy? A Practical Overview

This session will provide a brief synopsis of the recent SCC decisions in Fairmont and Jean Coutu. With those cases in mind, the following questions will be addressed:

  • What can planners do while working on files to create an appropriate trail that potentially can be relied on to support a rectification application?
  • How specific does one need to be about the intent and desired results?
  • If an "oopsie" does occur, what remedies, other than rectification, may be available (e.g., variation of trust order or order to correct corporate records under corporate law)?

John Agioritis,
MLT Aikins LLP, Saskatoon
Valerie Meier, Department of Justice Canada, Edmonton

12:20 pm - 
12:30 pm 
12:30 pm - 
1:30 pm

Wayne Adams, Canadian Tax Foundation, Ottawa
1:30 pm -
2:10 pm
Owner-Manager Remuneration Update

Tony Ozeroff, CPA, CA, Collins Barrow Calgary LLP, Calgary

2:10 pm -
2:50 pm
Preferred Share Dividends: The Expected, Unexpected, and Unintended

The preferred share rules were introduced under different economic and political circumstances.  This paper will review the taxation of preferred share dividends, with a focus on practical implications, and review the policy considerations for amending or eliminating the preferred share dividend rules.

Nancy Diep,
Blake, Cassels & Graydon LLP, Calgary
2:50 pm - 
3:00 pm 
3:00 pm - 
3:20 pm  
 Moderator:  Cheryl Gibson, QC, FCPA, FCA, Dentons Canada LLP, Edmonton
3:20 pm - 
4:00 pm  
Farming Taxation, with an Emphasis on Farm Succession

The paper and presentation will cover farm tax basics, the various inter vivos and testamentary farm rollovers and farm capital gains deduction, and common wills and estates issues that farmers and farm advisers encounter. 

J. Scott Bodie, Bennett Jones LLP, Calgary
Wesley Novotny, Bennett Jones LLP, Calgary

4:00 pm -
4:55 pm
Small Business Deduction Planning

This presentation will focus on the proposed changes to the small business deduction and their effect on existing corporate structures.  The speakers will summarize the changes, identify the corporate structures that are and are not affected, point out apparently unintended or unfair consequences (such as the impact on cooperative corporations and their members), and provide planning ideas for retaining access to the small business deduction where available.  

The speakers will also discuss key proposed definitions (“specified corporate income,” “specified partnership limit,” and “designated member”) and revisions to the existing definition of “specified partnership income.”  They will address the mechanics of the new regime and discuss alternative structures that still provide for the small business deduction.

Mike W. Harris, Dentons Canada LLP, Edmonton

4:55 pm -
5:00 pm

5:00 pm
  Program is subject to change. Please check back frequently for the most up-to-date version.

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9/19/2017 3:02:50 PM