68Th ANNUAL TAX CONFERENCE (2016)


ONLINE REGISTRATIONS ARE NOW CLOSED FOR THIS EVENT.

Please register onsite at the conference. The conference registration desk will be located in Exhibit Hall D of the Calgary Telus Convention Centre (North Building), 120 9 Ave SE, Calgary, AB T2G 0P3. 

Plenary Sessions (Sunday)

SUNDAY, NOVEMBER 27
9:00 am - 
12:00 pm

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.

Workshop 1: "Professional Responsibility in Tax Matters"  is pending approval for 3.0 hours of professionalism content.
 
12:00 pm -
1:00 pm 
Registration and Lunch | EXHIBIT HALL D (NORTH BUILDING)
 
OPENING SESSION
1:00 pm - 
1:45 pm
Annual General Meeting

Welcome Address
Heather L. Evans,
Executive Director and CEO, Canadian Tax Foundation

Opening Remarks
Bradley Sakich,
FCA, MSTax (US), PricewaterhouseCoopers LLP, Vancouver
Chair,
Canadian Tax Foundation

PLENARY SESSION | EXHIBIT HALL E (NORTH BUILDING)
1:45 pm - 
2:30 pm
Near-Term and Long-Term Outlook for Canada's Differing Regional Economies

Todd Hirsch,
Chief Economist, ATB Financial, Calgary
Luc Vallée,
Chief Strategist, Laurentian Bank Securities, Montréal

2:30 pm -
3:45 pm
Practitioners' Forum

Denise Allan, Vice-President, Tax, Cenovus Energy Inc., Calgary
Brett Anderson, Felesky Flynn LLP, Calgary
Paul Durant, CA, Paul B. Durant Professional Corporation, Cochrane
Kim G. C. Moody, FCA, TEP, Moodys Gartner Tax Law LLP, Calgary
 
3:45 pm -
4:15 pm 
Refreshment Break | EXHIBIT HALL E (NORTH BUILDING)
4:15 pm -
5:30 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.

Monica Biringer, Osler, Hoskin & Harcourt LLP, Toronto
Perry Derksen, Department of Justice, Vancouver
Anu Nijhawan, Bennett Jones LLP, Calgary

5:30 pm -
8:00 pm 
Opening Night Reception

Hosted by: Dentons Canada LLP

CONCURRENT SESSIONS

MONDAY, NOVEMBER 28

STREAMS

CORPORATE TAXATION
EXHIBIT HALL E (NORTH BUILDING)
INTERNATIONAL TAXATION
MACLEOD HALL BCD (SOUTH BUILDING)
OTHER SPECIALIST AREAS
MACLEOD HALL A (SOUTH BUILDING)
7:00 am -
8:00 am
BREAKFAST | EXHIBIT HALL C (NORTH BUILDING)
Hosted by: PricewaterhouseCoopers LLP

8:00 am -
9:00 am

Dealing with New Subsection 55(2) in Practice


Transfer Pricing and Dispute Resolution in a World of Changing Rules and Guidelines

Selected Issues for Private Corporations

9:00 am -
10:00 am

Current Transactions of Interest
 
Significant US Tax Developments
 
Governance and Tax Risk - Perspective of a Director, a CFO, a Tax Executive and an Investment Banker

10:00 am-
10:10 am
Questions Questions Questions
10:10 am-
10:40 am
REFRESHMENT BREAK | EXHIBIT HALL D (NORTH BUILDING)
Sponsored by: Blake, Cassels & Graydon LLP
10:40 am-
11:20 am
Commercial Vehicles – Select Issues in Defining Legal Relationships


IRS and Practitioner Panel: Updates on US Voluntary Disclosure Programs
Current Challenges by the CRA involving Fair Market Value
11:20 am-
12:00 pm
The Interaction of Specific Anti-avoidance Rules with the GAAR 

Understanding the Competent Authority Process
Leaving Canada’s New High Tax Rate Regime: Considerations, Tips and Traps
12:00 pm-
12:15 pm
Questions Questions Questions
12:15 pm-
2:00 pm
LUNCH | EXHIBIT HALL C (NORTH BUILDING)
Guest Speaker:
Jack Mintz, President's Fellow, School of Public Policy, University of Calgary
Hosted by: Thomson Reuters and McCarthy Tétrault LLP 

2:00 pm -
2:40 pm

Treatment of Takeover & Proxy Fights Costs and Costs to Deal with Activist Shareholders

US Citizens as Shareholders of Canadian Companies - Impact on Reorganizations and Other Canadian Tax Consequences

The Role of Technology in the Tax Functions of Today and Tomorrow 

2:40 pm -
3:20 pm

An Update on Flow-through Shares in the Energy Sector


New Reporting Obligations with a Focus on Country-by-Country Reporting

Pricing Carbon - Carbon Trading and Carbon Taxes
 
3:20 pm -
3:30 pm
Questions Questions Questions
3:30 pm -
4:00 pm
REFRESHMENT BREAK | EXHIBIT HALL D (NORTH BUILDING)

4:00 pm -
4:40 pm
Taxation of Hedges/Derivatives


In and Outbound structuring between Canada & Mexico
Income and Commodity Tax Considerations for the Sharing Economy
4:40 pm -
5:20 pm
Debt Restructuring Transactions - Issues, Strategies and Trends

Foreign Entity Classification Revisited

Large Corporation Objection and Appeal Process: What’s Wrong with this Picture?
5:20 pm -
5:30 pm
Questions Questions Questions
5:30 pm
7:30 pm
Reception
Hosted by: Osler, Hoskin & Harcourt LLP
9:00pm
12:00am
 Nightcap Reception
Hosted by: Bennett Jones LLP

Tuesday, November 29
6:30 am-
8:00 am
BREAKFAST | EXHIBIT HALL C (NORTH BUILDING)
Hosted by: Thorsteinssons LLP
8:00 am-
9:00 am
Issues Affecting Investments by Canadian Pension Plans in Private Equity, Infrastructure and Real Estate in Canada, U.S. and Europe

Beyond BEPS - Changes in European Tax Law: Practical Impact on Canadian Planning

Judges' Panel

9:00 am-
10:00 am
Tax Disputes and Litigation:  Tips and Traps for Planners

 A Detailed Review of the Back-to-back Loan Rules

Tax Policy Forum

10:00 am-
10:10 am
 Questions Questions  Questions 

10:10 am-
10:30 am
 
REFRESHMENT BREAK | EXHIBIT HALL D (NORTH BUILDING)

Sponsored by: Deloitte LLP


PLENARY SESSIONS | EXHIBIT HALL E (NORTH BUILDING)
10:30 am-
11:15 am
US Tax Reform and the Outlook for the Possibility of a Significant Reform under a New President

US Corporate Tax reform has been discussed for many years. Following the presidential election in 2016, is reform more or less likely? Robert Stack will provide his view on the opportunity for corporate reform in the coming years.

Robert Stack, U.S. Department of the Treasury, Washington, DC


11:15 am-
11:30 am
Judicial Update from the Tax Court of Canada

The Honourable Chief Justice Eugene P. Rossiter,
Tax Court of Canada, Ottawa

11:30 am-
11:50 am
Department of Finance Update

Brian Ernewein, General Director, Tax Policy Branch, Department of Finance, Ottawa

11:50 am-
12:20 pm
CRA Update

Bob Hamilton,
Commissioner of Revenue, Canada Revenue Agency, Ottawa

12:20 pm-
12:30 pm
Break
12:30 pm-
1:45 pm
CRA Roundtable Discussion

Sandra Mah,
DLA Piper (Canada) LLP, Calgary
Karen Nixon,
EY Law LLP, Calgary
Randy Hewlett,
Director, Financial Industries and Trusts Division ,Canada Revenue Agency, Ottawa
Stéphane Prud'Homme, Director, Reorganizations Division, Income Tax Rulings Directorate, Canada Revenue Agency, Ottawa

1:45 pm
Adjournment 
Back to top

CORPORATE TAXATION

MONDAY NOVEMBER 28
7:00am
Breakfast 
Moderator: John O'Callaghan, Department of Justice, Edmonton
8:00am

Dealing with the New Subsection 55(2) and 55(3)(a) in Practice

This session will analyze the practical application of the new purpose tests, examine the current position of safe income and discuss whether reliance on share redemption / repurchase (i.e. the new s.55(3)(a) exception) is the new panacea.

Doron Barkai, CPA, CA, Ernst & Young LLP, Calgary
Alexander Demner, Thorsteinssons LLP, Vancouver

9:00am

Current Transactions of Interest

This recurring session will examine interesting and unique public and private transactions involving acquisitions, dispositions, mergers, debt issuances and restructuring, recapitalizations, and loss utilizations.

Neal Armstrong, Davies Ward Phillips & Vineberg LLP, Toronto
Johanna Gerrie, KPMG LLP, Toronto
Peter Glicklich, Davies Ward Phillips & Vineberg LLP, New York 

10:00am Questions
10:10am
Refreshment Break
Moderator: Keith MacIntyre, CPA, CA, Grant Thornton LLP, Halifax
10:40am

Commercial Vehicles – Select Issues in Defining Legal Relationships

An examination of the various legal relationships — for example, partnerships, joint ventures, cost-sharing agreements, bare trust, agency, syndicates, associations, society, and trusts — that exist in Canada and the specific tax implications of each.

Heather DiGregorio, Burnet Duckworth & Palmer LLP, Calgary
Joanne Vandale, Osler, Hoskin & Harcourt LLP, Calgary

11:20am

The Interaction of Specific Anti-Avoidance Rules under the GAAR

This session will explore the interaction of specific anti-avoidance rules with the General Anti-Avoidance Rule (GAAR). Can steps taken to avoid a specific anti-avoidance rule leave taxpayers open to a GAAR challenge? Are steps taken to plan into the application of specific anti-avoidance rules subject to the GAAR?

Curtis Stewart, Fasken Martineau DuMoulin LLP, Calgary
Julie D'Avignon, Stikeman Elliott LLP, Calgary

12:00pm
Questions
12:15pm
Lunch
Moderator: Alycia Calvert, Ernst & Young LLP, Toronto
2:00pm

Treatment of Takeover & Proxy Fights Costs and Costs of Dealing with Activist Shareholders

This session will examine the treatment of these costs as ordinary business expenses in light of some recent court decisions.

Mark Jadd,
Dentons Canada LLP, Toronto
Yves St-Cyr,
Dentons Canada LLP, Toronto

2:40pm

An Update on Flowthrough Shares in the Energy Sector

In addition to providing a practical guide to the flowthrough share rules (including prescribed shares) in the oil and gas sector and the renewable energy sector, this session will consider issues involving flow-through shares in corporate transactions, such as amalgamations, windups, acquisitions of control, and farm-outs. Dealing with the flow-through share obligations of companies in financial distress will also be discussed.

Gregory Johnson, Bennett Jones LLP, Calgary
Wesley Novotny, Bennett Jones LLP, Calgary

3:20pm
Questions
3:30pm Refreshment Break
Moderator: Bruce Ball, FCPA, FCA, BDO Canada LLP, Toronto  
4:00pm

Taxation of Hedges/Derivatives

Fluctuating exchange rates and commodity prices may be leading to more hedging transactions. This session will examine the current state of hedges and derivatives in light of recent court decisions, legislative changes, and interpretations.

Nigel Johnston, McCarthy Tétrault LLP, Toronto
Roger Taylor, EY Law LLP, Ottawa

4:40pm

Debt-Restructuring Transactions — Issues, Strategies, and Trends

This session will address current issues affecting, and planning strategies for, debt-restructuring and debt-repurchase transactions.  The session will discuss debt-parking rules, new debt-parking rules for foreign currency denominated debt, debt slides, debt conversions, acquisition-of-control considerations, foreign-currency considerations, original issue discount (OID) considerations, deductibility of payments made by debtors and received by creditors in connection with a debt restructuring, and issues for non-resident debt holders.

Carrie Aiken, Blake, Cassels & Graydon LLP, Calgary
Johnson Tai, CA, PricewaterhouseCoopers LLP, Calgary

5:20pm
Questions
5:30pm
7:30pm
Reception
9:00pm-
12:00am
Nightcap Reception
TUESDAY NOVEMBER 29
7:00am
Breakfast 
Moderator: Cathie (Cathster) Brayley, Bull, Housser & Tupper LLP, Vancouver
8:00am

Issues Affecting Investments by Canadian Pension Plans in Private Equity, Infrastructure and Real Estate in Canada, U.S. and Europe

This session will include a discussion of the following:
  • Commonly used structures and Canadian issues arising with respect to investments in Canadian private equity, infrastructure, and real estate;
  • The impact of the potential tax measures described in the consultation document released by the Department of Finance on June 3, 2016 on commonly used structures for investments in Canadian private equity, infrastructure and real estate;
  • Commonly used structures and Canadian and U.S. issues arising with respect to investments in U.S. private equity and infrastructure funds;
  • Commonly used structures and issues arising with respect to investing in European private equity, infrastructure, and real estate; and
  • The potential impact of BEPS on commonly used European Investment structures.

William Corcoran,
Osler, Hoskin & Harcourt LLP, New York, NY
Jack Silverson, Osler, Hoskin & Harcourt LLP, Toronto


9:00am

Tax Disputes and Litigation:  Tips and Traps for Planners

This session will present tips and traps for tax planners, transaction advisors and their clients for the successful implementation of tax plans.  Using pointers from the case law where a tax plan has gone wrong, the session will examine each stage of a tax plan from pre-implementation and planning, through to implementation and post-implementation.  Given the Supreme Court of Canada’s recent decisions confirming the substantive right status of solicitor-client privilege, the session will also explore pro-active means of ensuring that privilege is maintained.

Cheryl Gibson, QC, FCPA, FCA, Dentons Canada LLP, Edmonton
Laurie Goldbach, Deloitte Tax Law LLP, Calgary

10:00am
Questions
10:10am Refreshment Break
 Back to top
TUESDAY NOVEMBER 29 - PLENARY
Moderator: Brent Perry, Felesky Flynn, Calgary
10:30am-
11:15am
US Tax Reform and the Outlook for the Possibility of a Significant Reform under a New President

US Corporate Tax reform has been discussed for many years. Following the presidential election in 2016, is reform more or less likely? Robert Stack will provide his view on the opportunity for corporate reform in the coming years.

Robert Stack, U.S. Department of the Treasury, Washington, DC


11:15am-
11:30am
Judicial Update from the Tax Court of Canada

The Honourable Chief Justice Eugene P. Rossiter, Tax Court of Canada, Ottawa

11:30am-
11:50am
Department of Finance Update

Brian Ernewein, General Director, Tax Policy Branch, Department of Finance, Ottawa

11:50am-
12:20pm
CRA Update

Bob Hamilton,
Commissioner of Revenue, Canada Revenue Agency, Ottawa

12:20pm-
12:30pm
Break
12:30pm-
1:45pm
CRA Roundtable Discussion

Sandra Mah,
DLA Piper (Canada) LLP, Calgary
Karen Nixon,
EY Law LLP, Calgary
Randy Hewlett,
Director, Financial Industries and Trusts Division ,Canada Revenue Agency, Ottawa
Stéphane Prud'Homme, Director, Reorganizations Division, Income Tax Rulings Directorate, Canada Revenue Agency, Ottawa

 
1:45pm
Adjournment 
 

INTERNATIONAL TAXATION

MONDAY NOVEMBER 28
7:00am
Breakfast 
Moderator: Ian Gamble, Thorsteinssons LLP, Vancouver 
8:00am

Transfer Pricing and Dispute Resolution in a World of Changing Rules & Guidelines

The changes to the OECD's transfer-pricing guidelines — changes that have arisen from the BEPS project — will affect the CRA's approach to transfer pricing and audits of past transactions. More audits and difficult approaches can only lead to more disputes. This session will examine:

  • Trends in CRA transfer-pricing audits and strategic considerations in responding to audit activity — impact of BEPS, contemporaneous documentation requests, audit queries, functional interviews, and requirements (domestic, foreign-based);
  • Disputing the transfer-pricing reassessment — choice of  forum (CRA Appeals, competent authority, or Tax Court of Canada?), procedural and tactical considerations (timing issues, impact on objection process, ability to post security); and
  • Role of the competent authorities in resolving transfer pricing disputes — a brief overview of MAP/BA process, recourse to the courts to enforce rights to or under the competent authority process (Chrysler, Sifto).

Clifford Rand,
Deloitte Tax Law LLP, Toronto
Michelle Sledz, CPA, CA, KPMG LLP, Calgary
Lori Whitfield, CPA, CA, Deloitte LLP, Vancouver

9:00am

Significant US Tax Developments

The session will address in some detail the proposed section 385 debt-equity regulations.  In addition, the session will provide a current status of M&A transactions and structuring, including the impact of inversion rule developments. Further, the session will address developments relevant to US investments by funds and institutional investors, such as “qualified foreign pension funds,” sovereigns and treaty-based platforms.

Peter Blessing, KPMG  LLP, New York, NY
Ronald Scharnberg, Norton Rose Fulbright US LLP, Houston, TX

10:00am 
Questions
10:10am
Refreshment Break
Moderator: Sébastien Rheault, Barsalou Lawson Rheault, Montréal
10:40am

IRS and Practitioner Panel: Updates on US Voluntary Disclosure Programs

This presentation will provide an overview of offshore compliance options offered by the Internal Revenue Service to U.S. taxpayers. The presentation will assist practitioners in choosing the best option for their clients to come into compliance with income tax and FBAR reporting obligations.  The presentation will review the terms of the 2014 Offshore Voluntary Disclosure Program (OVDP) and the details of the 2014 Streamlined Filing Compliance Procedures and emphasize the unique opportunities presented by the Streamlined Filing Compliance Procedures. The presentation will also distinguish the key differences between Streamlined Domestic Offshore (SDO) and Streamlined Foreign Offshore (SFO).

Roy Berg, Moodys Gartner Tax Law LLP, Calgary
Daniel Price, Office of Chief Counsel - Internal Revenue Service, Austin, TX

11:20am

Understanding the Competent Authority Process

With the globalization of markets, and the globalization of tax disputes, taxpayer interaction with competent authorities (Canadian and other jurisdictions) and interaction between competent authorities has become a more significant element in tax disputes.  This session will discuss how the Canadian competent authority interacts with other competent authorities under the mutual assistance procedure and otherwise and the role that taxpayers and their representatives play in this process.

Daryl Boychuk,
Canada Revenue Agency, Ottawa 
Jeffrey Shafer,
Blake, Cassels & Graydon LLP, Toronto

12:00pm
Questions
12:15pm
Lunch
Moderator: John Tobin, KPMG LLP, Calgary
2:00pm

US Citizens as Shareholders of Canadian Companies — Impact on Reorganizations and Other Canadian Tax Consequences

Domestic tax, estate, and wealth planning provides many opportunities to preserve wealth and to pass on this wealth to future generations of Canadian families. The strategies used to achieve desired family objectives will vary on the basis of specific family circumstances and objectives.  When spouses, children, or other family members become U.S. citizens, some of the tax strategies that are utilized by Canadian tax practitioners become complex, may produce unintended results, or may not work.  The objective of this session is to highlight some common tips to help Canadian tax practitioners with the traps that they may encounter when doing estate planning for Canadian families that include U.S. citizens who are beneficiaries and are intended to participate in the estate plan.  This presentation will also highlight some planning opportunities and considerations that could be utilized to achieve the desired objectives.

Kenneth Lobo
, Ruchelman PLLC, Toronto
Stanley Ruchelman
, Ruchelman PLLC, New York
Rahul Sharma
, Miller Thomson LLP, Toronto

2:40pm

New Reporting Obligations with a Focus on Country-by-Country Reporting

David Whiteley, CA, PricewaterhouseCoopers LLP, Calgary
Ivan Williams, CBV, PricewaterhouseCoopers LLP, Calgary

3:20pm
Questions
3:30 pm Refreshment Break
Moderator: Mike Maikawa, PricewaterhouseCoopers LLP, Toronto
4:00pm

Inbound and Outbound Structuring Between Canada & Mexico

This session will discuss tax-effective structuring for Canadian multinationals investing in Mexico and Mexican multinationals investing in Canada. The analysis will explore relevant intricacies and interplay between Canadian and Mexican tax law, relevant tax treaty provisions, and corresponding opportunities and pitfalls. The session will also focus on planning in respect of common and practical cross-border issues such as legal-entity selection, financing, employee mobility, and repatriation.

Mark Coleman, EY Law LLP, Calgary
Oscar López-Velarde, Ernst & Young LLP, Mexico

4:40pm

Foreign-Entity Classification Revisited

The CRA's recent announcement at the IFA roundtable that certain LLPs and LLLPs should be treated as corporations is causing taxpayers and their advisers to revisit the criteria used to determine whether an entity is a corporation or a flowthrough. This session will review (1) the criteria used to determine the classification and (2) the implications of the CRA's announcement.


Angelo Discepola, McCarthy Tétrault LLP, Montréal
Robert Nearing, McCarthy Tétrault LLP, Calgary

5:20pm  Questions
5:30pm
7:30pm
Reception
9:00pm
12:00am
Nightcap Reception
TUESDAY NOVEMBER 29
7:00am
Breakfast 
Moderator: Deirdre Choate, Husky Energy Inc., Calgary
8:00am

Beyond BEPS - Changes in European Tax Law: Practical Impact on Canadian Planning

This panel will examine how the European elements of planning structures for outbound investment from Canada and inbound investment to Canada are affected by recent changes in law and administrative policy in relevant European countries and the EU.

Mark van Casteren, Loyens & Loeff, The Netherlands
Andrew McBride,
Deloitte LLP, Calgary
Steve Suarez, Borden Ladner Gervais LLP, Toronto
Stéphane Tilkin, Deloitte LLP, Luxembourg

9:00am

A Detailed Review of the Back-to-Back Loan Rules

This session will involve a detailed review of the back-to-back rules that (i) were introduced in 2014 in the thin capitalization and interest withholding tax contexts, and (ii) were proposed in 2016 in the shareholder loan context and other withholding tax contexts (e.g., rent, royalties, character substitution, multiple-intermediary structures).

Jason Boland, KPMG LLP, Calgary
Christopher Montes, Felesky Flynn LLP, Calgary

10:00am
Questions
10:10am
Refreshment Break
Back to top
TUESDAY NOVEMBER 29 - PLENARY
Moderator: Brent Perry, Felesky Flynn, Calgary
10:30am-
11:15am
US Tax Reform and the Outlook for the Possibility of a Significant Reform under a New President

US Corporate Tax reform has been discussed for many years. Following the presidential election in 2016, is reform more or less likely? Robert Stack will provide his view on the opportunity for corporate reform in the coming years.

Robert Stack, U.S. Department of the Treasury, Washington, DC


11:15am-
11:30am
Judicial Update from the Tax Court of Canada

The Honourable Chief Justice Eugene P. Rossiter, Tax Court of Canada, Ottawa

11:30am-
11:50am
Department of Finance Update

Brian Ernewein, General Director, Tax Policy Branch, Department of Finance, Ottawa

11:50am-
12:20pm
CRA Update

Bob Hamilton, Commissioner of Revenue, Canada Revenue Agency, Ottawa

12:20pm-
12:30pm
Break
12:30pm-
1:45pm
CRA Roundtable Discussion

Sandra Mah,
DLA Piper (Canada) LLP, Calgary
Karen Nixon,
EY Law LLP, Calgary
Randy Hewlett,
Director, Financial Industries and Trusts Division ,Canada Revenue Agency, Ottawa
Stéphane Prud'Homme,
Director, Reorganizations Division, Income Tax Rulings Directorate, Canada Revenue Agency, Ottawa
 
1:45pm
Adjournment 

OTHER SPECIALIST AREAS

MONDAY NOVEMBER 28
7:00 am
Breakfast 
Moderator: H. Michael Dolson, Felesky Flynn LLP, Edmonton
8:00am

Selected Issues for Private Corporations

This session will highlight the many recent tax and legislative changes that have affected the taxation of private companies and their shareholders. Some of the more significant developments that will be discussed are as follows:   

  • Recent changes to the small business deduction;
  • Navigating the new rules in section 55;
  • The new eligible capital property regime – living with the new rules and some planning going forward;
  • Canada’s new high tax climate – planning for the future; and
  • What is coming down the pipeline? 

Grace Chow,
CPA, CA, TEP, Cadesky Tax, Toronto
Kenneth Keung, CA, TEP, Moodys Gartner Tax Law LLP, Calgary 

9:00am

Governance and Tax Risk - Perspective of a Director, a CFO, a Tax Executive and an Investment Banker

A tax executive, a chief financial officer, and a corporate director will provide their perspectives on understanding, managing, communicating, and monitoring tax risk.

John Brussa, Burnet Duckworth & Palmer LLP, Calgary
Michael Freeborn, CIBC World Markets, Calgary 
Wanda Opheim, Senior Vice President, Chief Accounting Officer, Enbridge Inc. Calgary
Brent Perry, QC, Felesky Flynn LLP, Calgary
Chris Saunders, Calgary

10:00am Questions
10:10am
Refreshment Break
Moderator: Dylan Hughes, CPA, CA, MNP LLP 
10:40am

Current Challenges by the CRA involving Fair Market Value

The valuation of an asset, tangible or intangible, can have a material effect on a taxpayer’s income taxes.  CRA-taxpayer controversies regarding “fair market value” continue, many unresolved values ultimately being adjudicated by the Tax Court of Canada. This session will address the major challenges taxpayers have been facing with respect to such matters as allocating corporate value among share classes, discount for embedded taxes in the valuation of a holding company, FMV of income and capital interests in discretionary trusts, valuing minority shares in family-controlled corporations and the effect of a key person on the value of a family-owned business.

Brandon Hodge, MNP LLP, Markham
Richard Wise, FCPA, FCA, TEP, MNP LLP, Montréal 

11:20am

Leaving Canada’s New High Tax Rate Regime: Considerations, Tips and Traps

Governments across Canada have responded to tough economic times and ballooning deficits with significant income tax rate increases on individuals. High income earners in Alberta have seen a 50% increase in provincial income tax rates and a 14% increase in federal income tax rates. Other provinces have raised taxes on high income earners as well. Some taxpayers have responded by moving to lower-tax jurisdictions and more could follow. In this presentation, we will consider what it takes to cease to be a Canadian tax resident, the tax consequences of such a move and certain potential tax planning opportunities available on emigration from Canada.

Carl Deeprose, Gowling WLG (Canada) LLP, Toronto
Brian Kearl, Gowling WLG (Canada) LLP, Calgary

12:00pm Questions
12:15pm
Lunch
Moderator: Deborah Toaze, Blake, Cassels & Graydon LLP, Vancouver
2:00pm

The Role of Technology in the Tax Functions of Today and Tomorrow 

Never before has tax been more important to governments, taxpayers, and other stakeholders.  Tax forms the basis for public spending, and governments want larger budgets to achieve their specific goals.  The reputation and well-being of companies are also being affected by external perceptions of how companies manage their tax affairs.  Companies need to respond in a clear and thoughtful way to a base of stakeholders that is much wider than ever before and includes not only tax authorities and governments, but also regulators, investors, non-governmental organizations (NGOs), the media, and the general public.  To achieve these objectives, companies are now required to focus on the quality and availability of data and to focus on the use of technology to improve efficiencies.  In this session, we will discuss technological challenges and best practices for a tax-strategy technology roadmap that is aligned with business priorities, and internal and external pressures that are driving the need for transformation, enhancing analytics and leveraging talents.  

John Gotts, CPA, CA, PricewaterhouseCoopers LLP, Oakville
Genevieve Groulx, CPA, CA, PricewaterhouseCoopers LLP, Calgary

2:40pm

Pricing Carbon — Carbon Trading and Carbon Taxes

This session provides a cross-country review and comparison of Canadian carbon regimes, including cap-and-trade and carbon levy regimes, as well as an overview of the material Canadian income tax considerations that are applicable to carbon regimes and carbon trading.

Torran Jolly, CPA, CA, KPMG LLP, Calgary
Dion Legge, Norton Rose Fulbright Canada LLP, Calgary

3:20pm
Questions
3:30pm Refreshment Break
Moderator: Amanda Doucette, Stevenson Hood Thornton Beaubier LLP, Saskatoon
4:00pm

Income and Commodity Tax Considerations for the Sharing Economy

With the aid of modern technology, the “sharing economy” is upending various traditional forms of business organization, with potentially significant tax consequences. The sharing economy is not really about “sharing” but, rather, it is a notional space where individuals, technology companies, retailers, and other businesses interact and transact in ways that require careful legal analysis in order for the tax risks to be understood and mitigated.


Ian Caines, Blake, Cassels & Graydon LLP, Toronto
Zvi Halpern-Shavim, Blake, Cassels & Graydon LLP, Toronto

4:40pm

Large Corporation Objection and Appeal Process: What’s Wrong with this Picture?

The large corporation objection and appeal rules were enacted in response to the fallout from the decision in Gulf Canada. Over time, the shortcomings of these rules have frustrated and created inefficiencies in the tax dispute resolution process. This session will discuss how the large corporation objection and appeal rules operate and the limitations arising by virtue of the interplay between these rules and other provisions of the Act. This session will also discuss the problems with the large corporation objection and appeal process and attempt to highlight practical CRA administrative solutions available and legislative solutions that may be needed to solve for the inefficiencies.

Jehad Haymour, Dentons Canada LLP, Calgary
Michael Munoz, Suncor Energy Inc., Calgary

5:20pm Questions
5:30pm
7:30pm
Reception
9:00pm
12:00am
Nightcap Reception
TUESDAY NOVEMBER 29
7:00am
Breakfast 

8:00am

Judges' Panel

This session will cover topical issues in Canadian tax litigation that are relevant to all tax practitioners, including remedies under administrative law when tax disputes are being considered.


Karen Janke-Curliss,
Department of Justice, Saskatoon
Patrick Lindsay,
PwC Law LLP, Calgary
The Honourable Justice Valerie Miller, Tax Court of Canada, Ottawa
The Honourable Justice John Owen, Tax Court of Canada, Ottawa

The Honourable Justice Wyman Webb, Federal Court of Appeal, Ottawa

9:00am

Tax Policy Forum

The 2016 federal budget announced that the Department of Finance would perform a review of tax expenditures. At the same time, tax payers are lobbying for additional incentives such as patent boxes and rules that facilitate intergenerational transfers of businesses. This session will review some tax preferences that may be examined in the tax expenditure review, along with other tax policy changes that might be considered by the new government.

Larry Chapman, FCPA, FCA, Canadian Tax Foundation, Toronto
Professor Kenneth McKenzie, Department of Economics, University of Calgary
Shawn Porter, CPA, CA, Deloitte LLP, Toronto
Dr. Lindsay Tedds, Associate Professor, University of Victoria

10:00am Questions
10:10am Refreshment Break
TUESDAY NOVEMBER 29 - PLENARY
Moderator: Brent Perry, QC, Felesky Flynn, Calgary
10:30am-
11:15am
US Tax Reform and the Outlook for the Possibility of a Significant Reform under a New President

US Corporate Tax reform has been discussed for many years. Following the presidential election in 2016, is reform more or less likely? Robert Stack will provide his view on the opportunity for corporate reform in the coming years.

Robert Stack, U.S. Department of the Treasury, Washington, DC


11:15am-
11:30am
Judicial Update from the Tax Court of Canada

The Honourable Chief Justice Eugene P. Rossiter, Tax Court of Canada, Ottawa

11:30am-
11:50am
Department of Finance Update

Brian Ernewein, General Director, Tax Policy Branch, Department of Finance, Ottawa

11:50am-
12:20pm
CRA Update

Bob Hamilton,
Commissioner of Revenue, Canada Revenue Agency, Ottawa

12:20pm-
12:30pm
Break
12:30pm-
1:45pm
CRA Roundtable Discussion

Sandra Mah,
DLA Piper (Canada) LLP, Calgary
Karen Nixon,
EY Law LLP, Calgary
Randy Hewlett,
Director, Financial Industries and Trusts Division ,Canada Revenue Agency, Ottawa
Stéphane Prud'Homme,
Director, Reorganizations Division, Income Tax Rulings Directorate, Canada Revenue Agency, Ottawa 
 
1:45pm
Adjournment 

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