June 5-6, 2018

rescheduled to
February 27-28, 2019
Metro Toronto Convention Centre (North Building) | 255 Front St West | Directions
This event will be streamed live via webcast. Click here for webcast registration details.
Program | Wednesday,February 27, 2019
12:00 pm 
Registration Desk Opens (A light lunch will be provided)

12:50 pm
Welcome Remarks

Jason Vincze,
PricewaterhouseCoopers LLP, Toronto

Moderator:  Jason Vincze, PricewaterhouseCoopers LLP, Toronto
1:00 pm -
1:45 pm
Keynote Session

Speaker: TBA

1:45 pm -
2:30 pm

Big Data, Big Brother and the Tax Function

Changes in technology have fundamentally altered the tax compliance landscape and the ability of tax authorities to gather and analyze taxpayer information. This session will review the trend to transparency, including global exchange of information agreements as well as non-traditional sources of data such as leaks through media organizations. The panelists will also consider the responses of taxpayers and their advisors.

Click here for an in-depth description of the presentation

Arthur Cockfield, Queen's University, Kingston
Pooja Mihailovich, Osler, Hoskin & Harcourt LLP, Toronto
Peter van Dijk,  PwC Canada LLP, Toronto
2:30 pm -
3:15 pm

Indirect Tax and E-Commerce

Globalization and the digital revolution has meant an acceleration of global tax frameworks and cooperation as governments grapple with tax leakage on supplies consumed in their jurisdictions. While the OECD principals of destination based place of supply rules, many tax authorities including Canada Revenue Agency lack the legislative and enforcement framework to capture non-resident suppliers of digitial goods. With the rise in 3D printing and other mediums for the delivery of goods and services, there are challenges with the characterization thereof and place of supply for indirect tax purposes. This session will cover the issues and challenges presented by the digital economy and trends to counter some of the challenges we are seeing globally.

Click here for an in-depth description of the presentation

Danny Cisterna, CPA, CA, Deloitte, Toronto
Sania Ilahi, 
EY LLP, Toronto

3:15 pm -
3:30 pm
3:30 pm -
3:45 pm

Moderator:  Laura Gheorghiu, Gowling WLG (Canada) LLP, Montreal
3:45 pm -
5:15 pm

Blockchain, Cryptocurrency and More: An Uneasy Fit with the Tax and Legislative Framework

This comprehensive session will feature experts from industry, government and private practice discussing industry trends and tax and legal issues in the rapidly evolving world of blockchain.  Specific focus will be given to two particular use cases, namely the taxation of cryptocurrency transactions and the tax and securities law issues associated with initial coin offerings (“ICOs”).  Prior to the session, conference participants will be sent a “blockchain primer” intended to provide baseline familiarity with the key terms and concepts.  The panel will provide a high level overview on the basics of blockchain and distributed ledgers and then illustrate their operation and analyze the issues that arise in these increasingly prevalent commercial transactions.  Topics to be covered include the following:

  • Initial coin offerings.
  • Characterization of cryptocurrency - commodity, security or currency – and associated income tax and sales tax results. 
  • When should transactions be taxed?
  • Tax treatment of various transactions – cryptocurrency exchanges and forks, barter transactions, donations
  • Tax treatment of different participants – investors, miners.
  • Traceability by tax authorities and concerns in relation to illicit activities.
  • Discussion of ICOs including what they are, how they work, how they make use of distributed ledger technology, different forms of coins/tokens.
  • Discussion of applicable securities law context (securities law issues and the approach of securities regulators).
  • Case studies of common ICO structures and relevant tax issues, including positions of the Canada Revenue Agency.

Click here for an in-depth description of the presentation
Click here for an in-depth description of the presentation

Matt Peters, Bennett Jones LLP, Toronto
Laura Gheorghiu, Gowling WLG (Canada) LLP, Montreal
Additional speaker TBA

5:15 pm - 
5:30 pm 
5:30 pm -
7:30 pm
Program | Thursday, February 28, 2019
7:30 am 
Registration and Breakfast

Moderator: Jay Goodis, Tax Templates Inc., Vaughan
8:30 am -
9:30 am

Technology is both an enabler and a disrupter.  This panel will address the challenges and opportunities presented by automation of the tax practice and will include representatives from industry, Canada Revenue Agency, and tax advisory practices. Areas to be explored include balancing opportunities for efficiencies and the challenges raised by automation of the tax practice and function,  including integrating software systems across finance, tax and other functions, data migration challenges, and the benefits and vulnerabilities associated with retention of books and records in electronic form.  The panel will explore how technology can be leveraged to harness efficiencies in the “commoditized” aspects of a tax practice while maintaining appropriate oversight and management of that work.  

Marie Blanchard, SNC Lavalin Group Inc., Montreal
Gino Piazza, CPA, CMA, KPMG LLP, Toronto

9:30 am -
10:15 am
Artificial Intelligence

Artificial intelligence is now making its presence felt in various fields. Tax is no exception. Using concrete examples based on business scenarios, this panel brings together perspectives from academia, the software industry, tax litigation, and the judiciary to contend with the key “big picture” questions that AI raises for tax professionals. How fast is AI developing in tax? What principles and safeguards should be guiding development of AI tools? Are the existing rules of ethics and professionalism sufficient to deal with AI? What questions should judges be asking themselves with respect to AI tools? How acute is the need to address gaps in the current legal framework governing privilege and confidentiality? What consequences will AI have for the future path of the law?

Click here for an in-depth description of the presentation

Professor Benjamin Alarie, University of Toronto, Faculty of Law
The Hon. Marshall Rothstein, C.C., Q.C., Osler, Hoskin & Harcourt LLP, Vancouver
Richard Tardif, Department of Justice, Ottawa

10:15 am -
10:30 am
10:30 am -
10:45 am

Moderator: Heather Evans, Canadian Tax Foundation, Toronto
10:45 am -
11:25 am
Sharing Economy

The presentation will address the latest developments with regards to the taxation of cross-border e-commerce and of the sharing economy in Canada, including potential legislative amendments, constitutional issues and the role of financial institutions. The presentation will also summarize the situation in other countries.

Using concrete examples, the presentation will explain the practical and technological issues associated with the avenues proposed by the governments, as well as the benefits and challenges of implementing tax compliance agreements.

Nicolas Cloutier, McCarthy Tétrault LLP, Montreal

11:25 am -
12:10 pm
Cybersecurity and Privacy

  • Issues, protocols and best practices for data exchanges between taxpayers and tax authorities
  • Privacy, maintaining privilege
  • Impact of automation and vulnerability of data
  • Country-by-country reporting: new threats?

Click here for an in-depth description of the presentation

Elisa Henry, 
Borden Ladner Gervais LLP, Montreal
Merlin Lapp, 
Canada Revenue Agency, Ottawa
Holly McClellan, 
PwC Canada LLP, Stamford, CT

12:10 pm - 
12:25 pm 
12:25 pm - 
1:30 pm

Moderator: Wayne Adams, Canadian Tax Foundation, Ottawa
1:30 pm -
2:30 pm
Evolution in Audit Approaches by Tax Authorities

  • Data analytics
  • Impact on tax base
  • Deployment of additional resources
  • Sharing of best practices globally

Click here for an in-depth description of the presentation

Brian Erard,
B. Erard & Associates, Washington, DC
Sue Murray, Canada Revenue Agency, Ottawa
Alan Plumley, Internal Revenue Service, Washington, DC

2:30 pm -
3:15 pm
Taxation of Intangibles

  • Value shift in the global economy
  • Implications to tax system
  • OECD response

Click here for an in-depth description of the presentation

Jinyan Li, 
Osgoode Hall Law School, Toronto
Angelo Nikolakakis, EY Law LLP, Montreal


3:15 pm - 
3:30 pm 
3:30 pm - 
3:45 pm  
Moderator: Siobhan Monaghan, KPMG Law LLP, Toronto
3:45 pm - 
4:30 pm  

Tax Incentives for Innovation and Transfer Pricing

This session will explore various tax incentives offered by the tax system to promote innovation in Canada, including SR&ED, multimedia and e-commerce tax credits, as well as IP regimes (including patent box systems and credits for innovative companies).  Finally, current trends and risks in the transfer pricing aspects of intangible assets and R&D services will be examined.

Click here for an in-depth description of the presentation

Sébastien Rheault, Barsalou Lawson Rheault, Montreal

4:30 pm -
5:15 pm

Taxation of Robots

  • What is the purpose of the tax system?
  • Tax policy and negative externality of job losses
  • South Korea as first adopter of tax on robots; other current developments

Click here for an in-depth description of the presentation

Speakers: TBA

5:15 pm -
5:30 pm

5:30 pm
  Program is subject to change. Please check back frequently for the most up-to-date version.

The Hon. Karen Sharlow, Osler, Hoskin & Harcourt LLP, Vancouver
The Hon. Karen Sharlow, Osler, Hoskin & Harcourt LLP, Vancouver

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12/10/2018 11:10:25 AM