Events

70th ANNUAL TAX CONFERENCE (2018)

 
VANCOUVER CONVENTION CENTRE, NOVEMBER 25-27, 2018
 
 The Annual Tax Conference is a three-day event compiled of workshops, plenary sessions, a pick of three concurrent streams, and social events. 
  » View Day 1 Sessions
(Sunday)
 » View Day 2 Sessions
(Monday)
» View Day 3 Sessions
(Tuesday)
 
 SUNDAY, NOVEMBER 25, 2018
DAY 1
 8:30 AM - 11:30 AM
»Sunday Morning Workshops

Extracurricular workshops offered on Sunday morning require an additional registration fee. They are not included in the conference registration. Click on the link above and book early! Attendance is limited.
 11:30 AM - 12:30 PM
REGISTRATION AND LUNCH
 12:30 PM - 1:15 PM
Annual General Meeting »
 SUNDAY AFTERNOON PLENARY SESSIONS
 1:15 PM - 2:15 PM
 Canadian Competitiveness, NAFTA, and Tax Reform in Canada »
2:15 PM - 2:45 PM
REFRESHMENT BREAK
 2:45 PM - 3:45 PM
Current Cases »
3:55 PM
OPENING DAY NETWORKING RECEPTION

Hosted by Dentons Canada LLP
 
MONDAY, NOVEMBER 26, 2018 
DAY 2
7:00 AM - 8:00 AM 
BREAKFAST
 CONCURRENT SESSIONS
CORPORATE TAXATION INTERNATIONAL TAXATION OTHER SPECIALIST AREAS
 8:00 AM - 9:00 AM
Rationalizing Your Structures in an Irrational World »
Cross-Border Investments in the Asia Pacific»
GAAR: 30 Years Later »
 9:00 AM - 10:00 AM
Recent Transactions of Interest »
US Tax Reform »
 Blockchain, Cryptocurrency, and More: An Uneasy Fit with the Tax and Legislative Framework »
 10:00 AM - 10:10 AM
QUESTIONS
 10:10 AM - 10:40 AM 
REFRESHMENT BREAK

Sponsored by Blake, Cassels & Graydon LLP
10:40 AM - 11:20 AM
Tax Planning for Investments in the Future »
 Inbound Investment »
 How Various Aggregation Rules Apply to Trusts »
 11:20 AM - 12:00 PM
Taxation of Partnerships: Then and Now »
Cross-Border Integration – Outbound Investment »
Understanding and Doing Business with Tax-Exempt Entities »
12:00 PM - 12:15 PM
QUESTIONS
12:15 PM - 2:00 PM
LUNCHEON
 
GUEST SPEAKER
The Honourable Christy Clark, Former Premier of BC


Hosted by Thomson Reuters and Mccarthy Tétrault LLP
2:00 PM - 2:40 PM
Paragraph 55(3)(a) – Developments Over the Last 10 Years »
Mergers & Acquisitions in Light of the US Tax Changes »
 Everything You Wanted to Know About Requirements for Information, But Were Scared to Ask »
2:40 PM - 3:20 PM
Taxation of Transaction Expenses »
Foreign Affiliate Update: Issues with Non-Corporate Vehicles »
Carbon Taxation »
3:20 PM - 3:30 PM
QUESTIONS
3:30 PM - 4:00 PM
REFRESHMENT BREAK
4:00 PM - 4:40 PM
The Evolving Role of Tax Insurance in Canadian Transactions »
Transfer Pricing:
Section 247 – 20 Years In »

 A Fabulous Review of the Recent Indirect Tax Cases That Even Income Tax Practitioners Will Be Interested in! »
4:40 PM - 5:20 PM
Executive Compensation »
Interest Deductibility »
(Can’t Get No) Satisfaction?:  Take a Look Beyond the ‘Fairness Provisions’ »
5:20 PM - 5:30 PM
QUESTIONS
5:30 PM
ADJOURNMENT
5:30 PM - 8:00 PM
MONDAY EVENING NETWORKING RECEPTION

Hosted by: Osler, Hoskin & Harcourt LLP
9:00 PM - 12:00 AM
NIGHTCAP RECEPTION

Hosted by: Bennett Jones LLP
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TUESDAY, NOVEMBER 27, 2018 
DAY 3
7:00 AM - 8:00 AM 
BREAKFAST

Hosted by: Thorsteinssons LLP
 CONCURRENT SESSIONS
 CORPORATE TAXATION  INTERNATIONAL TAXATION OTHER SPECIALIST AREAS
 8:00 AM - 9:00 AM
 Digitization/Automation of the Tax Function »
International Tax Issues That Get in the Way of Business »
 Judges' Panel »
 9:00 AM - 10:00 AM
The Specific Anti-Avoidance Rules: Recent Developments in and Updates on 84(2), 84.1, and/or 55(2) »
 Digital Taxation »
 CRA Audits of Large Corporations »
 10:00 AM - 10:10 AM
QUESTIONS
 10:10 AM - 10:30 AM 
REFRESHMENT BREAK
10:30 AM - 10:40 AM
Lifetime Contribution Award Ceremony »
TUESDAY AFTERNOON PLENARY SESSIONS
10:40 AM - 11:00 AM
Judicial Update from the Tax Court of Canada »
11:00 AM - 11:15 AM
Department of Finance Update »
11:15 AM - 11:30 AM
CRA Update »
11:30 AM - 12:45 PM
CRA Round Table Discussion »
12:45 PM
ADJOURNMENT

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FULL PROGRAM DETAILS 

PLENARY SESSIONS
 SUNDAY, NOVEMBER 25, 2018
11:30 AM - 12:30 PM | REGISTRATION AND LUNCH
12:30 PM - 1:15 PM
 Annual General Meeting
 1:15 PM - 2:15 PM
Canadian Competitiveness, NAFTA, and Tax Reform in Canada 

Speakers:
The Honourable Kevin G. Lynch
, BMO Financial Group, Toronto
The Honourable Pierre S. Pettigrew, Deloitte LLP, Toronto

2:15 PM - 2:45 PM  |  REFRESHMENT BREAK
 2:45 PM - 3:45 PM
Current Cases

A panel of experts with diverse backgrounds will discuss the impact and future applications of the legal principles that have emerged from recently decided cases, from the perspective of both taxpayers and tax authorities.

Speakers:
Bill S. Maclagan,
QC, Blake, Cassels & Graydon LLP, Vancouver 
Janette Pantry
, CPA, CA, EY LLP, Vancouver 
Michael Taylor
, Department of Justice, Vancouver

3:55 PM | OPENING DAY NETWORKING RECEPTION
 TUESDAY, NOVEMBER 27, 2018
10:30 AM - 10:40 AM
 Lifetime Contribution Award Ceremony
 10:40 AM - 11:00 AM
Judicial Update from the Tax Court of Canada 

 11:00 AM - 11:15 AM
Department of Finance Update

 11:15 AM - 11:30 AM
CRA Update

 11:30 AM - 12:45 PM
CRA Round Table Discussion

Speakers: 
R. Ian Crosbie
, Davies Ward Phillips & Vineberg LLP, Toronto
Patrick Lindsay
, PwC Law LLP, Calgary

12:45 PM  |  ADJOURNMENT

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CORPORATE TAXATION
CONCURRENT SESSIONS
 MONDAY, NOVEMBER 26, 2018
7:00 AM - 8:00 AM | BREAKFAST
8:00 AM - 9:00 AM
Rationalizing Your Structures in an Irrational World

In the last few years, there has been unprecedented change in the Canadian and international tax environments – for example, BEPS, US tax reform, and Canadian taxation of private corporations and their shareholders. Business owners and their advisers need to adapt existing business structures, or to structure new businesses, in light of these changes in order to manage overall tax cost.  This session will highlight specific areas to focus on and suggest possible changes to consider with a view to minimizing exposure to excessive taxation.

Speakers:
Steven Carreiro,
KPMG LLP, Burnaby 
Kirsten S. Kjellander
, Borden Ladner Gervais LLP, Vancouver

 9:00 AM - 10:00 AM
Recent Transactions of Interest

This session will provide an overview of recent transactions in traditional and emerging sectors.  New strategies to raise capital in the crypto and technology sectors, such as ICOs and SAFEs will be discussed.  In addition, recent acquisitions in the cannabis and mining fields will be examined.

Speakers: 
Darren Hueppelsheuser
, Norton Rose Fulbright Canada LLP, Calgary
Adrienne F. Oliver,
Norton Rose Fulbright Canada LLP, Toronto 
10:00 AM - 10:10 AM  |  QUESTIONS
10:10 AM - 10:40 AM  |  REFRESHMENT BREAK
10:40 AM - 11:20 AM
Tax Planning for Investments in the Future

The purpose of this paper is to address the issues facing private companies and their shareholders as a result of the changes that have been made to the Income Tax Act since 2014 in connection with investments.  Investments considered in this context will include cash that is surplus to the needs of the business, an investment portfolio, and real estate.  The goal is to address these matters in a way that will provide a practical roadmap to the issues that need to be addressed when the decision is made to hold the investments and distributions are made to the company’s shareholders.

Speakers: 
Ron Choudhury
, Miller Thomson LLP, Toronto
Grace Chow
, FCPA, FCA, TEP, Cadesky Tax, Toronto

 11:20 AM - 12:00 PM
Taxation of Partnerships: Then and Now

The hybrid treatment of partnerships as persons and as flowthrough entities under the ITA relative to their legal characterization raises ongoing issues with respect to the computation of income earned through a partnership.  This paper will provided an update on various technical issues but will also review some of the history of the taxation of partnerships (including inconsistencies in treatment of partnerships as persons or not) and the relevance of that history in undertaking a textual, contextual and purposive analysis of legislative gaps or unintended consequences under the ITA.

Speaker:
Nancy Diep
, Blake, Cassels & Graydon LLP, Calgary

12:00 PM - 12:15 PM  |  QUESTIONS
12:15 PM - 2:00 PM  |  LUNCHEON
2:00 PM - 2:40 PM
Paragraph 55(3)(a) – Developments Over the Last 10 Years

This presentation will focus on the developments affecting paragraph 55(3)(a) over the last 10 years.  It is aimed at practitioners who have experience with paragraph 55(3)(a) but would like to ensure that their knowledge of developments over the last 10 years is up to date.  Topics to be addressed are: the implications of the changes to subsection 55(2) and the CRA’s comments on paragraph 55(3)(a) in light of these changes; the proper interpretation of “series of transactions” for the purposes of paragraph 55(3)(a), taking into account the Supreme Court’s decision in Copthorne; and the implications of the changes that have been made to paragraph 55(3.01)(b).

Speaker:
Caroline Morin
, PwC Canada, Calgary
L. Alan Rautenberg, Bennett Jones LLP, Calgary 

 2:40 PM - 3:20 PM
Taxation of Transaction Expenses

T
his session will attempt to answer the following questions:

I. To the extent that expenses are attributed as capital expenditures to minority shareholders how realistic is it to do so?  Is a minority shareholder who will never even know the identity of – must less have a conversation with – the professional firm “representing” him or her really “incurring” an expense?
II. To the extent that companies incur expenses “on behalf” of their shareholders, do they have legal authority to do so?
III. To the extent that the CRA suggests that company-paid transaction expenses are shareholder benefits, does doing so make sense for minority shareholders who arguably have not “received” anything?
IV. Could it be argued that management or larger shareholders who actively participate in a transaction (and arguably realize more direct benefit from professional services because they are able to directly engage the professional advisors) should bear a disproportionate amount of the transaction expenses?
V. Is it appropriate that public companies may be treated differently than widely held private companies in terms of transaction expenses?
Speaker: 
Michael Coburn
, Fasken, Vancouver

3:20 PM - 3:30 PM  |  QUESTIONS
3:30 PM - 4:00 PM  |  REFRESHMENT BREAK
4:00 PM - 4:40 PM
The Evolving Role of Tax Insurance in Canadian Transactions

This session will address the following:
 - Using insurance solutions to overcome tax hurdles and manage tax risk
 - Bespoke tax insurance vs. rep & warranty insurance
 - Types of risks that can be insured
 - The process for incorporating tax insurance into a live transaction
 - Impact of insurance on reps & warranties and other transaction documents
 - Canadian tax implications if insurance is paid
 - Privilege considerations
Speakers:
Tom Cartwright
, Ironshore International, United Kingdom
Andrew Spiro
, Blake, Cassels & Graydon LLP, Toronto

 4:40 PM - 5:20 PM
Executive Compensation

This session will provide a comprehensive status report and update on the taxation of executive compensation and benefits, including options and stock-based plans such as RSUs and DSUs.  Developments in the law, administrative practice, and current areas of focus for CRA audits will be covered.  The impact of US tax reform on common cross-border compensation strategies will also be considered.  Finally, practical issues in the implementation and ongoing management of plans that tax and human resources departments need to consider will be discussed.

Speakers: 
D. Brett Anderson
, Felesky Flynn LLP, Calgary
Matthew R. Kraemer
, Felesky Flynn LLP, Calgary

5:20 PM - 5:30 PM  |  QUESTIONS
5:30 PM  |  ADJOURNMENT
 TUESDAY, NOVEMBER 27, 2018
7:00 AM - 8:00 AM | BREAKFAST
8:00 AM - 9:00 AM
Digitization/Automation of the Tax Function 

This panel of industry experts will discuss the profound impact of technology on the tax function of Canadian corporations.  What is the current state of the technology and how can progressive organizations effectively migrate to the tax function of the future?   Issues to be considered include resource allocation, training of talent, management of tax reporting and risk, and the relationship of the tax function with other departments and executive leadership.  Where might tax departments fall short and what are the optimal mitigation strategies?

Speakers: 
Deirdre Choate
, VP, Tax & Treasurer, Husky Energy Inc., Calgary
Grant Lee, VP, Tax, HSBC Bank Canada, Vancouver
Heather O'Hagan
, VP, Head of Tax for Canada, Thomson Reuters, Toronto

Panel Moderator: 
Gino Piazza
, CPA, CA, CMA, CITP, Partner, Tax Transformation and Technology, KPMG LLP, Toronto

 9:00 AM - 10:00 AM
The Specific Anti-Avoidance Rules: Recent Developments in and Updates on 84(2), 84.1, and/or 55(2)

This session will provide a comprehensive update on developments in relation to specific anti-avoidance rules in the Income Tax Act, including subsection 84(2), section 84.1, and subsection 55(2).  Recent jurisprudence and technical interpretations will be covered, as will the interplay between specific anti-avoidance rules and GAAR in statutory interpretation.  

Speakers:
H. Michael Dolson
, Felesky Flynn LLP, Edmonton
Kenneth Keung, CA, CPA (CO, USA), TEP, Moodys Gartner Tax Law LLP, Calgary
Josh Kumar, Thorsteinssons LLP, Toronto

10:00 AM - 10:10 AM  |  QUESTIONS
10:10 AM - 10:40 AM  |  REFRESHMENT BREAK
10:40 AM - 12:45 PM  |  PLENARY SESSIONS »
12:45 PM  |  ADJOURNMENT

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INTERNATIONAL TAXATION
CONCURRENT SESSIONS
 MONDAY, NOVEMBER 26, 2018
7:00 AM - 8:00 AM | BREAKFAST
8:00 AM - 9:00 AM
Cross-Border Investments in the Asia Pacific

This session will discuss tax-effective structuring for Canadian companies investing in China, India, and Singapore.  The analysis will explore relevant intricacies and interplay between Canadian tax law, and the relevant tax law in each jurisdiction; tax treaty provisions; and corresponding opportunities and pitfalls. The session will also focus on structuring and planning in respect of common and practical cross-border issues such as legal-entity selection, financing, and repatriation.

Speakers:
Marc-André Marchand
, Deloitte LLP, Hong Kong
Christopher Roberge
, Deloitte LLP, Hong Kong
 
 9:00 AM - 10:00 AM
US Tax Reform

Almost one year later, how has U.S. tax reform affected Canadian multinationals? Who are the winners and who are the losers? This session will explore certain aspects of tax reform and how they have affected, and will continue to guide, the way Canadian multinationals manage their tax burdens. The pitfalls, uncertainties, and opportunities created by this milestone reform will be explored – specifically, those related to interest expense limitation, hybrid provisions, the BEAT, and FDII.

Speakers:
Roy Berg
, Moodys Gartner Tax Law LLP, Calgary
Dennis Metzler
, Deloitte LLP, Toronto
Maruti Narayan
, DLA Piper (US) LLP, New York
Paul Seraganian
, Osler, Hoskin & Harcourt LLP, New York

10:00 AM - 10:10 AM  |  QUESTIONS
10:10 AM - 10:40 AM  |  REFRESHMENT BREAK
10:40 AM - 11:20 AM
Inbound Investment

This session will provide an update on current tax matters that affect foreign investment in Canada, including the current Canadian view and the tendancies of the tax authority regarding treaty shopping, MLI, use of a ‘principal purpose test’ (PPT) in Canada’s treaties, interpretational issues with the PPT, recent views and experiences of technical matters related to the back-to-back loan rules for withholding tax and thin cap, and the foreign affiliate dumping rules. The session will also address at a high-level the recent US tax reform changes that are affecting US investors with current and future investments in Canada, including the impact of these changes on existing business models. 

Speakers:
Richele Frank
, CPA, CA, KPMG LLP, Vancouver
Andrew Wong, Torys LLP, Toronto

 
 11:20 AM - 12:00 PM
Cross-Border Integration – Outbound Investment

This session will provide, among other things, an update on the calculation of the fully distributed tax rates applicable to various Canadian outbound structures coming into the United States. The revised calculations will reflect changes to US and Canadian tax rates as well as to the Canadian foreign affiliate regime. The session will also provide additional examples that will highlight specific US tax reform provisions and changes to the Canadian foreign affiliate regime. These examples will go beyond the models in the earlier paper. The US tax reform provisions illustrated will include the following, among others: new earnings-stripping provisions, enhanced cost-recovery provisions, base erosion/anti-abuse provisions, and provisions applicable to certain hybrid structures and to foreign-derived intangible property. The session will also explore the application of the Canadian foreign affiliate regime to the same models.

Speakers:
Tim Barrett,
Thorsteinssons LLP, Toronto 
Kevin J. Duxbury
, CPA, CA, KPMG LLP, Vancouver

12:00 PM - 12:15 PM  |  QUESTIONS
12:15 PM - 2:00 PM  |  LUNCHEON
2:00 PM - 2:40 PM
Mergers & Acquisitions in Light of the US Tax Changes

Recent US tax reform has brought numerous changes, particularly with regard to international taxation, that will significantly impact cross-border mergers and acquisitions.  This session will examine the US tax changes that will impact mergers and acquisitions in Canada, and certain Canadian tax and structure considerations that result from such changes.

Speakers:
Jennifer Hanna
, MNP LLP, Calgary
Kenneth Saddington
, Goodmans LLP, Toronto

 2:40 PM - 3:20 PM
Foreign Affiliate Update: Issues with Non-Corporate Vehicles

This session will be a review of selected technical and practical issues that can arise under the foreign affiliate and surplus rules when a vehicle other than a “standard” corporation (such as a non-traditional corporation, a partnership or a trust) is located within a foreign affiliate structure that is ultimately owned by a Canadian-resident corporation. This review will include on overview of recent entity classification developments, recent amendments on corporations without share capital (section 93.2), hybrid entity issues (including US LLCs), issues with partnerships and foreign affiliates, trusts (in general and including sections 94, 94.2 and 93.3).

Speakers:
Tina Korovilas
, Grant Thornton LLP, Toronto
Drew Morier
, Osler, Hoskin & Harcourt LLP, Toronto

3:20 PM - 3:30 PM  |  QUESTIONS
3:30 PM - 4:00 PM  |  REFRESHMENT BREAK
4:00 PM - 4:40 PM
Transfer Pricing: Section 247 – 20 Years In

It has been approximately 20 years since section 247 was introduced, but there remains significant uncertainty regarding its application.  Despite an increased number of transfer pricing audits and disputes in Canada, disputes are hard and expensive to resolve and outcomes are hard to predict. Among other things, the scope of 247(2)(a)/(c) and 247(2)(b)/(d), and the conditions required for the CRA to re-characterize transactions, remain unclear.

As our understanding of section 247 has been developing in Canada, there have been numerous developments both at the international level and in other jurisdictions around the world.  These developments, such as the BEPS initiative and the revised OECD transfer pricing guidelines, undoubtedly will have an impact on Canadian transfer pricing, both generally and with respect to specific issues such as the re-characterization of transactions.  Some countries have resorted to legislative measures, such as the BEAT in the US and the diverted profits tax in the UK and Australia, to reduce the incentive taxpayers sometimes have to engage in aggressive transfer pricing.

The panelist will explore these matters, and provide insight on the challenges that taxpayers, practitioners, the CRA, the courts and the legislators will face in the years to come.

 
Speaker:
Christopher J. Montes
, Felesky Flynn LLP, Calgary

 4:40 PM - 5:20 PM
Interest Deductibility

The G20/OECD BEPS Action 4 Final Report rejected thin capitalization rules, such as Canada’s, based on a fixed debt:equity ratio. Instead, it recommended that countries should adopt earnings stripping rules to limit the deduction of net interest expenses by resident entities to 10 – 30 percent of EBITDA. The European Union and the United States recently adopted earnings stripping rules that are broadly similar to the rules recommended in the BEPS Action 4 Report. Against the background of these recent developments, this panel discussion will explore whether Canada should enact new restrictions on the deduction of interest and, if so, what shape those restrictions should take.

Speakers: 
David G. Duff, Peter A. Allard School of Law, UBC, Vancouver
Kevin Milligan,
Vancouver School of Economics, UBC Vancouver
 
Panel Moderator: 

Brian Arnold, Canadian Tax Foundation, London 
5:20 PM - 5:30 PM  |  QUESTIONS
5:30 PM  |  ADJOURNMENT
 TUESDAY, NOVEMBER 27, 2018
7:00 AM - 8:00 AM | BREAKFAST
8:00 AM - 9:00 AM
International Tax Issues That Get in the Way of Business

A panel consisting of 2 tax practitioners and a government representative will discuss Canada’s international tax rules, including a discussion of how they may present challenges for Canadian-based businesses that operate outside Canada or within an international group and of whether modifications to the rules or interpretations thereof may be possible and of the challenges posed by amending the rules or the interpretations thereof.  
Speakers: 
Tony Ancimer
, FCPA, FCA, Deloitte LLP, Toronto
Shawn Porter, CPA, CA, Deloitte LLP, Toronto

 9:00 AM - 10:00 AM
Digital Taxation

One of the major challenges at present concerns tax policy reform aimed at the digital economy. The established legislative and treaty framework clearly does not adequately address the fundamentally different business models posed by the digital economy or their implications for the corporate tax base. Key questions concern how to establish sufficient presence to support taxation and the determination of profit allocation across jurisdictions.  The OECD and the EU have each proposed solutions, but consensus among member states is elusive.  In Canada, no action has been taken to date except in the province of Quebec.  This international panel of experts will provide both an update and their perspectives on the prospect of achieving a workable solution.

Speakers:
David Bradbury,
OECD, Paris 
Allison Christians,
McGill University, Montreal 
Rosalie Wyonch
, C.D. Howe Institute, Toronto


Panel Moderator:
Elinore Richardson
, EMKDM Global Consulting Inc., Toronto

10:00 AM - 10:10 AM  |  QUESTIONS
10:10 AM - 10:40 AM  |  REFRESHMENT BREAK
10:40 AM - 12:45 PM  |  PLENARY SESSIONS »
12:45 PM  |  ADJOURNMENT

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OTHER SPECIALIST AREAS
CONCURRENT SESSIONS
 MONDAY, NOVEMBER 26, 2018
7:00 AM - 8:00 AM | BREAKFAST
8:00 AM - 9:00 AM
GAAR: 30 Years Later

Speakers:
Ed Kroft
, Q.C., Blake, Cassels & Graydon LLP, Vancouver
P. Mark Meredith
, KPMG Law LLP, Vancouver
Deen Olsen
, Department of Justice, Ottawa

Panel Moderator: 
Tim Duholke, FCPA, FCA, Kabro Strategies, Vancouver

 9:00 AM - 10:00 AM
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 arising 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 basic familiarity with the key terms and concepts.  The panel will provide a high-level overview of the basics of blockchain and distributed ledgers and then illustrate their operation and analyze the issues that arise in these increasingly prevalent commercial transactions.

Speakers:
Laura Gheorghiu
, Gowling WLG (Canada) LLP, Montreal
Matthew Peters
, Bennett Jones LLP, Toronto
Amy Trafford, Canada Revenue Agency, Ottawa 

10:00 AM - 10:10 AM  |  QUESTIONS
10:10 AM - 10:40 AM  |  REFRESHMENT BREAK
10:40 AM - 11:20 AM
How Various Aggregation Rules Apply to Trusts

The aggregation provisions contained in the Act with respect to the rules governing affiliated, arm’s length, related and associated persons are complex and multifaceted.  Trusts can be amorphous and opaque in nature.  As a result, the application of these aggregation rules to trusts can be challenging.  This session will discuss certain technical issues in applying the various aggregation rules to trusts, as well as practical and policy implications arising from these issues. 

Speakers:
Kenneth R. Hauser, Kenneth R. Hauser Law Corp., Kamloops
Jeffrey T. Love
, KPMG Law LLP, Toronto

 11:20 AM - 12:00 PM
Understanding and Doing Business with Tax-Exempt Entities

Investment-orientated tax exempt entities (“TEEs”) such as pension funds play a significant role in the Canadian economy. Increasingly, Canadian businesses of various sizes are looking to TEEs as a critical source of financing and investment. Issues that will be covered in this session will include how TEE’s status under the Income Tax Act (and the desire to preserve such status) may impact planning and structuring considerations when advising on a proposed investment or financing.  The importance to TEEs of adhering to non-tax legislative or regulatory requirements when making investment will also be considered.  The session will also review potential limits on tax exempt status including the application of GST, Part XIII of the Income Tax Act and penalty provisions.  The purpose of the session will be to provide insight to both practitioners who regularly work directly with TEEs and practitioners who have clients that may have dealing with TEEs.

Speakers:
Hersh Joshi
, CPA, CA, Ontario Teachers' Pension Plan, Toronto
Jack Silverson,
Osler, Hoskin & Harcourt LLP, Toronto 

12:00 PM - 12:15 PM  |  QUESTIONS
12:15 PM - 2:00 PM  |  LUNCHEON
2:00 PM - 2:40 PM
Everything You Wanted to Know About Requirements for Information, But Were Scared to Ask

The Canada Revenue Agency has taken an aggressive approach to gathering information from taxpayers.  This approach includes requests that comprehensive questionnaires be completed and extensive detailed information be provided.  To motivate a taxpayer to comply with these requests for information, the CRA may advise that a failure to voluntarily comply will result in the issuance of a formal Requirement to Provide Information.

This session will review the CRA’s power to issue a Requirement and how a taxpayer might respond to the issuance a Requirement. The session will also consider the general limits on the rights of the CRA to compel the production of information and how a taxpayer may try to enforce these limits.

Speaker:
Joel A. Nitikman
, Dentons Canada LLP, Vancouver

 2:40 PM - 3:20 PM
Carbon Taxation

By 2019, we expect to see some form of carbon pricing across Canada and it will be different in most provinces and territories.  Our paper will provide a summary of the current carbon pricing structures (carbon tax, cap and trade, etc.) in Canada and highlight some compliance challenges.  It will also provide information on some of the energy incentive programs available.  

Speaker:
Tracey Osmond
, FCPA, FCGA, Grant Thornton LLP, Calgary\

3:20 PM - 3:30 PM  |  QUESTIONS
3:30 PM - 4:00 PM  |  REFRESHMENT BREAK
4:00 PM - 4:40 PM
A Fabulous Review of the Recent Indirect Tax Cases That Even Income Tax Practitioners Will Be Interested in!

This session will include a discussion of the following cases:
1. Koskocan (2016 TCC 277) 
2. 407 ETR (2017 FCA 220) 
3. North Shore Power (2018 FCA 9) 
4. Onenergy (2018 FCA 54) 
5.Callidus Capital (2017 FCA 162) 
6. Jayco (2018 TCC 34) 
Speaker:
Robert Kreklewetz
, Millar Kreklewetz LLP, Toronto

 4:40 PM - 5:20 PM
(Can’t Get No) Satisfaction?:  Take a Look Beyond the ‘Fairness Provisions’

This section highlights some of the alternative means of obtaining “satisfaction” beyond the typical “taxpayer relief” provisions of the Income Tax Act.  While the latter have had more playtime over the years (and are the subject of many more decisions of the Federal Courts), there are some real indy hits out there that should be added to your playlist.

Speakers:
Allison Blackler
, EY Law LLP, Vancouver
Daniel Sandler
, EY Law LLP, Toronto

Panel Moderator:
David Jacyk
, Osler, Hoskin & Harcourt LLP, Vancouver

5:20 PM - 5:30 PM  |  QUESTIONS
5:30 PM  |  ADJOURNMENT
 TUESDAY, NOVEMBER 27, 2018
7:00 AM - 8:00 AM | BREAKFAST
8:00 AM - 9:00 AM
Judges' Panel

Speakers:
Pooja Mihailovich
, Osler, Hoskin & Harcourt LLP, Toronto
Michelle Moriartey
, Legacy Tax + Trust Lawyers, Vancouver

 9:00 AM - 10:00 AM
CRA Audits of Large Corporations

This session features senior tax executives of large corporations sharing their experiences of the current challenges and best practices when dealing with the CRA during the audit stage through the objection and appeal process.  The discussion will provide candid insights into (i) navigating the heavy administrative and legislative requirements imposed on large corporations; (ii) managing audit relationships that can be adversarial; (iii) how this landscape can affect the broader administration and governance of a tax function of a large corporation.

Speakers:
Nojan Abrary
, VP, Tax, Methenax Corp., Vancouver
Michael Munoz, Vice President, Suncor Energy Inc., Calgary
Nick Pantaleo, FCPA, FCA, SVP, Corporate Finance, Rogers Communications, Toronto
Douglas J. Powrie, VP, Tax, Teck Resources Ltd., Vancouver

10:00 AM - 10:10 AM  |  QUESTIONS
10:10 AM - 10:40 AM  |  REFRESHMENT BREAK
10:40 AM - 12:45 PM  |  PLENARY SESSIONS »
12:45 PM  |  ADJOURNMENT

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9/24/2018 11:13:58 PM