Ontario Tax Conference

Keeping Tax Practitioners Informed

Monday and Tuesday, October 29-30, 2012

Doubletree by Hilton - Toronto Airport
655 Dixon Road

[Fees] [Cancellation]
[Program Committee]
[Hotel Accommodation] 

  This program has been accredited by the Law Society for 0.5 Professionalism Hour(s).  This program is also eligible for up to 12.25 Substantive Hours. 
Conference App

Renew your acquaintances, create new alliances with other tax professionals and government officials,
and benefit from great networking opportunities.

Monday, October 29, 2012
7:30 am  Registration 
7:30 am -
8:30 am


Sponsored by

8:15 am -
8:30 am
Opening Remarks 
Larry Chapman, FCA
Executive Director and Chief Executive Officer of the Canadian Tax Foundation

8:30 am - 
9:20 am

Moderator: Larry Chapman, FCA, Canadian Tax Foundation

Current Issues

A review of recent legislative and administrative developments in federal and provincial tax law, including significant changes arising from the expected Technical Bill.

Gabriel Baron CA, Ernst & Young LLP, Toronto
Stefanie Morand, McCarthy Tétrault LLP, Toronto

9:20 am -
10:10 am

Current Cases

A review of recent decisions from the Tax Court, the Federal Court of Appeal, and the Supreme Court that affect owner-managed businesses and private companies.

Robin MacKnight, Wilson Vukelich LLP,  Markham
Perry Truster, FCA, Truster Zweig LLP,  Richmond Hill
10:10 am -
10:25 am
10:25 am -
10:45 am

Refreshment break

Sponsored by
Minden Gross LLP

10:45 am -
11:25 am

Moderator: Marco Dolfi, Miller, Canfield, Paddock & Stone

Cross-Border Potpourri Issues for Small and Mid-Sized Businesses (Canada-US Treaty Update)

This session will discuss the following:

  • Deemed permanent establishment services provisions in Article V, paras. 9 and 10
  • Basic review of Article XXIX-A - Limitations on Benefits
  • LLC-ULC structures
  • Financing of Canadian operations
  • Investing into the United States

James Hutchinson, Miller Thomson LLP, Toronto
Giancarlo Di Maio, CA, PricewaterhouseCoopers LLP, Windsor

11:25 am -
12:00 pm

Tax Principles of Family Law

This session wil focus on the intersection of Ontario's Family Law Act with the Income Tax Act, highlighting the income tax implications of separation and divorce.

Some of the topics to be discussed will include:

  • Definition of "spouse" for income tax and family law purposes
  • Transfers of property (e.g. principal residence, RRSPs, securities, rental properties)
  • Income attribution
  • Rollovers available to separated spouses
  • Tax aspects of child and spousal support
  • Deductibility of legal and accounting fees

    Llana Nakonechny, Dickson MacGregor Appell LLP, Toronto
    Andrew Freedman, CA, Duff & Phelps, Toronto
12:00 pm -
12:15 pm
12:15 pm - 
2:00 pm


Luncheon Speaker:

Kim G.C. Moody CA, TEP
Moodys LLP Tax Advisors, Calgary

Sponsored by
Thorsteinssons LLP

2:00 pm -
2:35 pm

Moderator: Mark Jadd, Heenan Blaikie LLP

Practical Considerations of Claiming an ABIL and the Capital Gains Exemption

ABIL  - When do you have one and how do you maximize it?

  • Traps and arrangements to avoid
  • Capital gains exemption  - Tips and structures to maximize it
  • Traps to avoid
  • Pros and cons of crystallization
Manu Kakkar, CA, Manu Kakkar CA Inc, London
Nancy Yan, CA, Cadesky and Associates LLP, Toronto
2:35 pm - 
3:10 pm

Incentive Compensation for Small and Medium-Sized Private Companies

This session will review and analyze some of the compensation alternatives available to small and medium-sized private companies, including:

  • Three-year bonus deferrals
  • DSUs for longer-term incentives
  • Employee profit-sharing plans
  • Appreciation rights
  • Stock grants and options
  • Permitting key employees to render services through a business trust
  • Retirement compensation arrangements for key employees
  • Group RRSPs
Paul Carenza, Cassels Brock & Blackwell LLP, Toronto
3:10 pm -
3:25 pm
3:25 pm -
3:45 pm
Refreshment break
3:45 pm -
4:20 pm

Moderator: Timothy Fitzsimmons, Fraser Milner Casgrain LLP

Indirect Taxes - Overview of Issues Relating to Commonly Encountered Indirect Taxes 

This session will examine sales tax, customs and excise issues encountered by small and medium-sized businesses.

Jaime Seidner, Fraser Milner Casgrain LLP, Toronto    
Maurizio Ulgiati, Deloitte & Touche LLP, Mississauga 
4:20 pm - 
4:55 pm 

Estate Planning – Tips and Traps

This paper will not attempt to look at the topic of estate planning from a global perspective, but will instead focus on the following three issues:

  • The taxation of RRSPs and RRIFs at the time of death when left to a surviving spouse or common-law partner
  • The transfer of locked-in accounts at the time of death
  • The taxation of segregated funds at the time of death
Christine Van Cauwenberghe, Investors Group, Winnipeg
4:55 pm - 
5:10 pm
5:10 pm  -
7:30 pm   

Evening Reception

Sponsored by
Fraser Milner Casgrain LLP


Tuesday, October 30, 2012
7:30 am
7:30 am -
8:30 am  


Sponsored by
Cassels Brock and Blackwell LLP

8:30 am -
9:20 am

Moderator: Phil Friedlan, Friedlan Law

Revisiting the Attribution Rules - Income Splitting, 75(2), 74.4, and the Kiddie Tax 

  • Review of main attribution rules and recent jurisprudence
  • Dealing with the unexpected application of subsection 75(2)
  • Dealing with the kiddie tax
  • Income splitting - practical planning suggestions 
  • Application of GAAR to the rules
Maria Elena Hoffstein, Fasken Martineau DuMoulin LLP, Toronto
Michelle Lee, CA, PricewaterhouseCoopers LLP, Toronto
9:20 am -
9:55 am

Owner-Manager Remuneration Update  

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 on how and through which kind of vehicle to earn income. 

Don Carson, CA, MNP LLP, Markham
9:55 am -
10:10 am
10:10 am -
10:30 am

Refreshment break

Sponsored by
BDO Canada LLP

10:30 am -
11:45 am
Moderator: Wayne Adams, Canadian Tax Foundation

Issues Arising in the Purchase and Sale of a Business and Transfer of Assets

Highlights of this session's discussion points include:
  • Tax elections
  • Allocation of purchase price
  • Tax considerations for the seller
  • Tax considerations for the buyer
  • Deferred payments and earnouts
  • Non-compete payments
  • Tax losses
  • Tax clearance certificates on sales of Canadian business and impact of new taxable Canadian property definition
  • Tax considerations in deal structuring
  • Initial inquiries and information gathering
  • Contingent amounts
Ron Choudhury, Aird & Berlis LLP, Toronto
Doug Connell, CA, Deloitte & Touche LLP, Toronto
11:45 am -
12:00 pm
12:00 pm -
1:15 pm

Sponsored by

1:15 pm -
1:50 pm

Moderator: Ruth Cummings, KPMG LLP

Shareholder Agreements

This session will examine two typical examples of structures common in owner-managed businesses; two equal individual shareholders and shareholders holding companies for the same individuals.

Using these examples, the presentation wil address income tax issues arising from typical provisions in shareholder agreements such as

  • Survivorship arrangements
  • Control of the corporation

Evelyn Schusheim, Cummings Cooper Schusheim Berliner LLP, Toronto

1:50 pm -
2:50 pm

Due Diligence in the Tax Practice - Practical Guide to Critical Due Diligence Steps for Practitioners: What Do You Need To Do on a Practice Management Level? 

This session will discuss due diligence from two perspectives:

  1. The reasonable due diligence steps that should be performed when assisting a client with transactions where tax issues are significant, including the acquisition or disposition of a business or property
  2. The due diligence that is reasonable for a practitioner to perform when relying upon representation for a client in order to provide tax advice or to prepare a tax filing. 
Joan Jung,  Minden Gross LLP, Toronto
Steven Hurowitz, CA, KPMG LLP, Toronto
2:50 pm - 
3:00 pm
3:00 pm -
3:20 pm
Refreshment break
3:20 pm -
4:30 pm
Moderator: Sandy Hale-Malhinha, BDO Canada LLP 

Tax Administration Panel

A panel of representatives from the Canada Revenue Agency offices in Ottawa will provide updates on recent interpretive, administrative, and compliance developments relevant to small and medium-sized businesses.  
Joe Monaco, Simpson Wigle Law LLP,  Hamilton
Fiona Harrison, Canada Revenue Agency, Ottawa
Jeff Sadrian, Canada Revenue Agency, Ottawa 
4:30 pm -
4:45 pm
4:45 pm Adjournment

 Other Sponsors


Program Printing
Sponsored by:

Conference Binder
Sponsored by:



 Program Committee 

Paul Carenza
Cassels Brock & Blackwell LLP
Don Carson
Ruth Cummings
Marco Dolfi
Miller, Canfield, Paddock & Stone
Timothy Fitzsimmons
Fraser Milner Casgrain LLP
Phil Friedlan
Friedlan Law
Sandy Hale-Malhinha
BDO Canada LLP
James Hutchinson
Miller Thomson LLP
Mark Jadd
Heenan Blaikie LLP
Robin MacKnight
Wilson Vukelich LLP
Ken Lancaster
Grant Thornton LLP
John Loukidelis
Simpson Wigle Law LLP

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   Member Non-member
Early Bird 
(register & pay on or before October 5)
$795 $1295
Regular (after October 5) $945 $1295
Government  $745  $895
Young Practitioner  $645 $795
Full-time Academic  $195 $195
Full-time Student  $100 $100 
Conference Materials**  
Conference Binder  $50.00 
Electronic   $0.00
** Important notes:

Conference Materials (papers and powerpoint presentations) will be posted on the CTF web site prior to the conference. The conference registration fee includes electronic access to these materials; the registration fee does not include a printed copy of the materials.

If you would like to receive a Conference Binder, please select this option when registering; you will be charged an additional $50.00 to cover the cost of the binder.

Sharing a single registration between two or more individuals is not permitted. Access to conference meetings, meal functions, and related events will be limited to registrants wearing valid name badges.

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Hotel Accommodation


Out-of-town registrants should make their hotel reservations directly with the Doubletree Hotel. The hotel is holding a block of rooms for registrants on a first-come, first-served basis until September 28, 2012, after which they will be released. To access the special discounted rates, please identify yourself as a member of the Ontario Tax Conference.

Reservations Direct Line: 416.244.1711
Toll-Free Number: 1.800.668.3656
Reservations Direct Fax: 416.244.7281
Reservations Email:

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If you are unable to attend the conference, registration may be transferred to one other individual. Please submit the name of the substituted delegate to Robyn Corrigan at up to three business days prior to the start of the conference. After that, the substitution will be accepted only at the conference site. If substitution is not an option, written notice of cancellation will be accepted by the Conference Department until Monday, October 22, 2012. Individuals who cancel their registration prior to this deadline will receive a refund, less a $100 administration fee, at the conclusion of the conference. We regret that we can not issue refunds for notices of cancellation received after this deadline.

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6/23/2018 1:44:13 PM