Events

2017 ATLANTIC PROVINCES TAX CONFERENCE



Sobey School of Business | Saint Mary's University | 923 Robie Street | Halifax

Program
Friday, November 3, 2017
8:30 am -
9:30 am
Workshop Registration Desk Opens & Breakfast
 
9:30 am -
12:00 pm
Workshops
 
12:00 pm -
12:45 pm
Main Conference Registration Desk Opens & Lunch

Plenary Session 
 
12:45 pm -
1:00 pm 

Opening Remarks

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

1:00 pm -
2:10 pm
Current Issues Forum

    Danielle Desjardins, CPA, CA, PricewaterhouseCoopers LLP, Halifax
    Douglas Wright, Cox & Palmer, St. John's

    2:10 pm -
    2:20 pm
    Questions
    2:20 pm -
    2:40 pm


    Concurrent Sessions
     

    2:40 pm -
    3:40 pm
    Partnerships & Cost Sharing + Small Business Deduction Issues and Opportunities

    The evolution of the small business deduction has closed the door on certain corporate structures while opening the door for others.  The use of partnerships and cost sharing arrangements are becoming in vogue again.  As a result, this panel will examine some of the important aspects of properly structuring a partnership and cost sharing arrangement.  This panel will also discuss other potential strategies that can be utilized to minimize the impact of the small business deduction changes; as well as, provide an update on the most recent Department of Finance proposed amendments to section 125.

    Nathalie Amirault, CPA, CA, Grant Thornton LLP, Halifax
    R. Darren Baxter,
    QC, TEP, McInnes Cooper, Halifax

    Cross-Border Tax Issues with a Business Focus

    The world is a much smaller place than it was 20 years ago. Corporations are finding that to be successful in business means operating more international than ever before.  However, with this global reach there comes the intricacies of navigating the tax compliance of multiple national jurisdictions.  This presentation and paper will cover the compliance issues facing Canadian companies when they do business outside of Canada as well as the compliance faced by non-resident companies coming and doing business in Canada.  Also an area to be considered is looking at compliance issues faced by companies operating in the global e-commence space.

    Justin Heisler, CPA, CA, Emera Inc. Halifax
    Darlene Shaw, CPA, CA, Collins Barrow Nova Scotia, Dartmouth

    3:40 pm -
    3:50 pm
    Questions  Questions 
    Plenary Session
     
    4:00 pm -
    4:50 pm

    A Study of Private Corporations

    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 signaling a relook at Section 84.1.  This panel will discuss both the areas of concern, Finance’s intended policy response, and share thoughts on strategies to minimize unintended adverse impacts on clients.

    Jeffrey Blucher, TEP, McInnes Cooper, Halifax
    Dwayne MacKay, CPA, CA, TEP, PricewaterhouseCoopers LLP, Halifax

    4:50 pm -
    5:00 pm
    Questions 
    5:00 pm -
    5:40 pm
    Tax Administration Update

    Ted Gallivan, Assistant Commissioner, Canada Revenue Agency, Ottawa

     
    5:40 pm -
    7:30 pm    
    Reception

    Time to relax and catch up with your fellow conference attendees. Join us for appetizers and drinks after the last session on Friday, November 3.
    Saturday, November 4, 2017
    7:30 am -
    8:30 am
    Breakfast
    Plenary Session


    8:30 am -
    9:20 am
    Related Party Transactions Involving Private Corporations

    A Related Party Transaction is a business deal or arrangement where a special relationship exists between the parties. Transactions between related parties and non-related parties, even when they  accomplish the same objective, generally have to be structured in different ways and rarely is the tax treatment equivalent to the parties involved.  The test is based upon if the parties are “dealing with each other at arm’s length” and related parties are deemed not to be, and can be restricted under various provisions of the Income Tax Act.  Unrelated Parties are free to deal without these same restrictions however, they can be deemed not to be dealing at arm’s length if they are acting in concert together.  If this occurs, the same restrictive provisions can apply as to related parties.  As the transactions are becoming more sophisticated between purchaser and vendor, where is the line where unrelated parties would be deemed not to be dealing with each other at arm’s length and where is it a valid business transaction. This presentation will explore some of these considerations and also some of the ways in which transactions can be structured where related parties are involved. 

    Natalie Woodbury, TEP, BoyneClarke LLP, Halifax
    Kevin Yuill, CPA, CA, BDO Canada LLP, Halifax

     
    9:20 am -
    9:30 am
    Questions
    Concurrent Sessions
     

     
    9:40 am -
    10:40 am
    Structuring Hybrid Transactions

    An alternative to treating a transaction as either a sale of assets or a sale of shares is to structure a transaction as a hybrid transaction.  Hybrid transactions can allow a vendor to take advantage of some of the tax efficiencies of a share sale and at the same time allow a purchaser to take advantage of the tax efficiencies of an asset sale. This top will discuss the mechanics and considerations involved in planning for an executing a hybrid transaction.

    Earl MacLeod, CPA, CA, MNP LLP, Dartmouth
    Christine Pound, Stewart McKelvey, Halifax

    Tax Impediments to Charitable & Not-for-Profit Operations

    This session seeks to illustrate what income and excise tax hurdles must be overcome by third sector organizations that seek revenue diversification, i.e. non-traditional forms of third sector income, as part of the case for regulatory reform/ clarification.

    Melinda Fleming, Grant Thornton LLP, Halifax
    Rob Miedema, BoyneClarke LLP, Dartmouth


    10:40 am - 
    10:55 am
    Questions
     Questions
    10:55 am -
    11:15 am

    Plenary Session


    11:15 am - 
    12:15 pm
     
    Subsections 55(2): A Practical Perspective

    It has been more than two years since the changed to subsection 55(2) were introduced in the 2015 Federal Budget.  This presentation and  paper will cover the impact the changes have had on both routine and complex tax planning with an emphasis on what can be done in light of the new rule and CRA’s published interpretations.

    Jennifer Campbell, Patterson Law, Halifax
    Jason Conrad, CPA, CA, Belliveau Veinotte Inc. Halifax

     
    12:15 pm -
    12:30 pm
    Questions
    12:30 pm 
    Adjournment

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    8/23/2017 1:43:31 PM