Advance registrations are now closed for this event. Please contact Conferences@ctf.ca for any inquiries.

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Please note, no hardcopy material will be available onsite. We encourage you to download the material in advance.

The registration desk will open at 7:00 am [PDT]  on Monday, September 24 and will remain open for the duration of the conference. Please check in at the registration desk, located on the second level of the Vancouver Convention Centre, West Building (1055 Canada Place)

Monday, September 24, 2018
7:00 am -
8:00 am
Registration & Breakfast
8:00 am -
8:15 am 
Opening Remarks

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

Moderator: Jeffrey Foreman, CPA, CA, D&H Group LLP, Vancouver 
8:15 am -
9:15 am
Current Cases

A review of recent decisions that affect owner-managed businesses and private companies.

Robert Carvalho, Thorsteinssons LLP, Vancouver 

Ryan Hoag, MNP LLP, Vancouver

9:15 am -
10:15 am
Current Issues

A review of recent legislative and administrative developments in federal and provincial tax law, including a review of federal and provincial budgets for 2018.

Chris Gimpel, CPA, CA, Deloitte LLP, Vancouver 
Grant Russell, KPMG Law LLP, Vancouver 
10:15 am -
10:25 am
10:25 am -
10:45 am

Moderator: Helena Plecko, Helena Plecko Law, Port Moody 
10:45 am -
11:45 am
TOSI and Alternative Remuneration Strategies

This session will analyze the new TOSI provisions, with topics including what is subject to TOSI and what isn’t, structures that might avoid the application of TOSI, and other methods of remuneration that might be used to avoid the application of TOSI. 

Stephanie J. Daniels,
Farris, Vaughan, Wills & Murphy LLP, Vancouver 
Trevor Goetz, CPA, CA, Grant Thornton LLP, Vancouver

11:45 am -
11:55 am
11:55 am -
1:40 pm

Guest Speaker

Brent Osborne, CPA, CA, Deloitte LLP
presenting on
"Cryptocurrency & Blockchain: The Basics"

Moderator: J. Andre Rachert, Cook Roberts LLP, Victoria
1:40 pm -
2:20 pm

Taxation of Cryptocurrency

Blake Allan, CPA, CA, MNP LLP, Vancouver 
Ron Dueck, Farris, Vaughan, Wills & Murphy LLP, Vancouver 

2:20 pm -
3:00 pm
Protecting Privilege

This session will discuss privilege in the context of taxation and in connection with accountants involved in a transaction, and it will focus on the following topics:

  • the IGGillis and Lizotte decisions
  • the difference between solicitor-client privilege, litigation privilege, and common interest or transactional privilege; the circumstances in which these different types of privilege may apply; and the circumstances in which a client or accountant should be mindful of establishing privilege
  • when it is appropriate — if an accountant is involved in a transaction — to structure the engagement so as to ensure that privilege is established, and how this structuring is done (what are the practice do’s and don’ts — for example, with respect to the accountant’s engagement letter to the lawyer)
  • the appropriate course and conduct for the accountant after privilege is established, and what the accountant needs to be aware of to ensure that privilege is not tainted or surrendered
  • whether privilege applies for the purposes of US law if the Canadian accountant provides US-related structuring advice (and vice versa — whether privilege applies for the purposes of Canadian law if a US accountant provides structuring advice related to Canada).

Laurie A. Goldbach,
Borden Ladner Gervais LLP, Calgary
Shannon James, Borden Ladner Gervais LLP, Calgary 

3:00 pm -
3:10 pm
3:10 pm -
3:30 pm

Moderator: Frank W. Quo Vadis, Koffman Kalef LLP, Vancouver
3:30 pm - 
4:25 pm

Private Corporations: Part I
An overview of changes between 2015 and 2018 

The last five years have seen an avalanche of legislative changes affecting the planning for private companies and their shareholders. This session provides a high-level review of the last five years of tax changes that have affected private company planning, in order to provide a basis for discussion both of best practices and of planning options that have arisen out of these changes.  

Legislative changes reviewed will include:

  • passive investment proposals;
  • tax on split income (TOSI);
  • proposals to eliminate or reduce the ability to multiply the small business deduction, such as specified corporate income;
  • changes to the eligible capital property rules;
  • overhaul of subsection 55(2) and paragraph 55(3)(a); and
  • graduated rate estate/life interest trust proposals. 

David Christian, Thorsteinssons LLP, Vancouver
Dawn Tipton,
CPA, CA, TEP, Grant Thornton LLP, Victoria

4:25 pm -
5:20 pm 
Private Corporations: Part II
The impact on common structures and best practices 

Following Part I's review of private corporation changes, our panelists will explore different structures in the new tax landscape. The panel will discuss new traps found in common structures, and best practices to stay onside the maze of new legislation. The panel will also highlight structures that no longer work and will consider new planning ideas.

David Baxter, Thorsteinssons LLP, Vancouver
Alexander Demner,
Thorsteinssons LLP, Vancouver 
5:20 pm -
5:30 pm
5:30 pm -
7:30 pm    

Networking Reception

Tuesday, September 25, 2018
7:15 am -
8:15 am
Registration & Breakfast
Moderator: Kevin Wong, CPA, CA, MNP LLP, Vancouver 
8:15 am -
9:15 am
US Tax Reform: Outbound (Corporate)

Significant changes to the US tax system have turned Canada's competitive tax advantage on its head. These changes call for responses from the Canadian government. They also require Canadian corporations with activities in the US to re-examine and adjust their structures for the short-term, mid-term, and long-term. 
This session will outline key relevant changes to Canadian multinationals such as the interest expense limitation, full expensing of qualified property, net operating losses, base erosion and anti-avoidance tax (BEAT), foreign derived intangible income (FDII), and anti hybrid rules. The speakers thereafter offer insights into some current focuses by multinational companies.

Jenny Li,
PwC Canada, Vancouver 
Kristine Tom, PwC Canada, Vancouver

9:15 am -
10:15 am
US Tax Reform: Inbound

This session discusses the impact of US tax reform on Canadians investing or working in the United States; on US citizens living in Canada; and on Canadian corporations with US shareholders. Topics include the new transition tax, changes to the estate and gift tax, a new passthrough deduction, and the new global intangible low-taxed income (GILTI). This session will also discuss strategies to address these changes."

Kevyn Nightingale, CA, CPA (ON), CPA (IL), TEP, MNP LLP, Toronto
David Turchen, CPA, CA, CPA (WA), MNP LLP, Abbotsford

10:15 am -
10:25 am
10:25 am -
10:45 am

Moderator: Sindy Wong, CPA, CA, Smythe LLP, Vancouver 
10:45 am -
11:30 am
A New Era of Real Estate Taxation: BC Tax Measures and Other Selective Tax Issues

The presenters will cover various tax-related measures announced in the federal budget (tiered partnerships) and the BC budget (speculation tax, enhanced property transfer tax, enhanced foreign buyer’s tax, school tax), with a focus on how these measures can affect a real estate development project from the time that land is purchased through the rezoning, permitting, pre-sales, and construction periods, and finally to completion. The paper will highlight, in addition, some of the common income tax issues and traps (e.g., multi-tier partnership structures, capital vs. inventory, rollover transactions, capitalize vs. expense) that can arise throughout the real estate development cycle.

Roque Hsieh,
CPA, CA, KPMG LLP, Vancouver 
Henry Liao, CPA, CA, KPMG LLP, Vancouver 

11:30 am -
12:15 pm
Planning with Trusts: Challenges and Opportunities

Trusts are an essential part of the planning toolkit and address many important non-tax-related purposes common to estate planning, such as incapacity and asset protection.  Trusts have also been a critical part of both inter vivos and testamentary tax planning in Canada and elsewhere for many years. However, tax changes over the last several years have fundamentally altered the tax-effectiveness of trusts, raising questions as to their continued utility and role for Canadian planners. This session will address the impact of legislative change on common planning structures (e.g., the estate freeze, income-splitting, and immigration trusts), and it will discuss the future of trusts in light of this change.

Richard Weiland, Clark Wilson LLP, Vancouver 

12:15 pm -
12:25 pm
12:25 pm -
1:30 pm
Moderator: Corinne Grigoriu, Osler, Hoskin & Harcourt LLP
1:30 pm -
2:10 pm

Business Transitions Other than Sale

When business owners seek an exit other than a third-party sale, the tax implications of a family business succession or a management or employee buyout will determine the timing of the exit, the cash flow needs of the parties, and some of the central mechanics of the exit plan. In this session, various buyout structures will be revisited in light of the recent significant changes to section 55 and of other provisions in the ITA that are commonly relied on. Other important considerations, such as appropriately allocating tax risk or tying the exit into the owner’s estate planning, will also be examined. 

Catherine (Cathie) Brayley, Miller Thomson LLP, Vancouver
Regan O’Neil, Miller Thomson LLP, Calgary

2:10 pm -
2:55 pm

Optimizing Extractions from Private Corporations

Surplus extraction received an inordinate amount of attention in 2017, when Finance announced (but subsequently abandoned) changes to section 84.1 and the addition of section 246.1. This session will review recent jurisprudence, legislation, GAAR commentary, and CRA technical interpretations in order to identify approaches to surplus extraction that should survive a review by CRA.  Topics will include pipeline planning (both post-mortem and in preparation for emigration) and hybrid share/asset sales.

Erin Swint,
CPA, CA, Squire and Company, Abbotsford

2:55 pm -
3:05 pm
3:05 pm -
3:25 pm

Moderator: Laura M. Peach, Legacy Tax + Trust Lawyers, Vancouver 
3:25 pm - 
4:25 pm
Best Practices When Representing Taxpayers In The CRA’s New Audit Regime

The panelists will focus on current trends in enforcement and administration, including net worth assessments, the “postal code” project, electronic funds transfers involving foreign jurisdictions, dealing with the Appeals Division at the objection stage, taxpayer relief, service complaints, and changes to the Voluntary Disclosure Program. The panel will also cover areas of increased CRA scrutiny, including CCPC status, SR&ED, and employment expenses.  

Alistair G. Campbell, Legacy Tax + Trust Lawyers, Vancouver 
Michelle Moriartey, Legacy Tax + Trust Lawyers, Vancouver 
Shane Onufrechuk, FCPA, FCA, KPMG LLP, Vancouver
4:25 pm -
4:35 pm

4:35 pm Adjournment


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