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SUNDAY, DECEMBER 1, 2019
|9:00 AM - 12:00 PM | WS-A | Room 522A
|THIS WORKSHOP HAS BEEN APPROVED FOR 3.0 PROFESSIONALISM HOURS BY THE LAW SOCIETY OF ONTARIO
View accreditation information here.
|Ethics & Professionalism -- The Practice of Tax in Canada in 2019: Navigating the Opportunities and Challenges
This highly-interactive session facilitated by three practitioners will explore two inter-related topics: (i) Learning & Mentorship, and (ii) Technology.
Items addressed as part of the Learning & Mentorship component of the workshop will include talent development, upward and downward mentorship relationships, navigating (and capitalizing on) inter-generational differences, and profile building.
The Technology component of the workshop will include an overview of the impact of technology on the tax practice, and an interactive presentation on how iPads and similar tablet devices can be used in your practice to make you more productive. The iPad/tablet discussion will include an overview of some of the best productivity apps, firmware productivity features, accessories/extensions, and device and data security.
This workshop is designed to appeal to (and will benefit from participation by) practitioners at all stages of their careers.
Angelo Discepola, McCarthy Tétrault LLP, Montreal
Salvatore Mirandola, McCarthy Tétrault LLP, Toronto
Stefanie Morand, McCarthy Tétrault LLP, Toronto
|9:30 AM - 12:00 PM | WS-B | Room 522B
Pursuing Excellence in Tax Litigation
Al Meghji, Osler, Hoskin & Harcourt LLP, Toronto
What makes an excellent tax litigator? This workshop will offer the perspectives of a tax litigator and a former Supreme Court of Canada Justice. The session will cover various aspects of effective tax advocacy including how to master the art of competitive storytelling by simplifying and humanizing a case. Also addressed will be: strategic decision-making, how to approach areas of vulnerability in a case and how to address the “morality” issues at play in tax avoidance cases. The session will also cover the role of the courts in tax cases (contrasted with the role of the legislature) and the factors that influence judicial decision-making. This session will offer young lawyers aspiring to be excellent tax litigators practical advice on how to separate themselves from the pack and rise from average to excellent.
The Hon. Marshall Rothstein, CC, QC, Osler, Hoskin & Harcourt LLP, Vancouver
The Hon. Justice David W. Stratas, Federal Court of Appeal, Ottawa
|9:30 AM - 12:00 PM | WS-C | Room 523A
|Remedies for a Taxpayer – Remission, Relief, Rescission, or Rectification?
This workshop will review current remedies available for taxpayers beyond the tax appeal. It considers the tools of rectification and rescission, and its limitations. The workshop will then undertake an in-depth study of taxpayer relief and remission orders and appeals mechanisms for each remedy.
Amanda S.A. Doucette, TEP, Stevenson Hood Thornton Beaubier LLP, Saskatoon
Samuel Singer, Assistant Professor, Thompson Rivers University, Kamloops
Douglas Wright, Cox & Palmer, St. John's
|9:00 AM - 12:00 PM | WS-D | Rooms 518A, 518B & 518 C
|Mastering the Art of Examinations-in-chief and Cross Examinations
Oral advocacy and witness management are skills that require continual refinement. This hands-on workshop will provide an opportunity to practice and sharpen your examination-in-chief and cross-examination skills.
Each participant will be provided with brief fact scenarios in advance of the workshop and will be required to conduct an examination-in-chief and a cross examination before a Judge. Feedback will be provided by the Judges at the end of the presentations.
The Hon. Justice Dominique Lafleur, Tax Court of Canada, Ottawa
The Hon. Justice Patrick J. Boyle, Tax Court of Canada, Ottawa
The Hon. Justice Wyman W. Webb, Federal Court of Appeal, Ottawa
Important note: this workshop is specifically
targeted to junior litigators. This session will be presented in English & French. You will be
required to select your language of preference at the time of
|9:30 AM - 12:00 PM | WS-E | Room 519A [SOLD OUT]
|Tax on Split Income (TOSI)
Based on the recent CRA technical interpretation and other published guidance, this workshop will provide an overview of the TOSI rules using practical case studies, including tax-planning opportunities in respect of the following topics:
- Excluded business;
Derek de Gannes, CPA, CA, RSM Canada, Toronto
- Excluded shares;
- No related business;
- Inheritance continuity.
Tom Flaig, CPA, CA, RSM Canada, Edmonton
Sankalp (Sunny) Jaggi, CPA, CA, CFF, RSM Canada, Toronto
Marlin Miller, CPA, CA, RSM Canada, Calgary
|9:30 AM - 12:00 PM | WS-F | Room 519B [SOLD OUT]
|Computation of Surplus Pools
• A brief overview of Canada’s surplus regime, specifically:
— the importance of maintaining surplus balances for foreign affiliates
• Illustrative examples on common surplus computation issues, including:
— a review of key concepts and computation rules in determining surplus balances
— trips and traps in the preparation of surplus balances (such as information gathering roadblocks, currency selection, deemed active business income and Canadian Part I rules, “blocking deficits” and 95(2)(f.1) carve-out etc.);
— best practices and practical solutions to address common issues
Talora Farovitch, VP, International Tax, Brookfield Properties, Toronto
Marianne Thompson, CPA, CA, PwC Canada, Oakville
|9:30 AM - 12:00 PM | WS-G | Room 525 [SOLD OUT]
This workshop will employ a combination of lectures,
case studies and group discussion to deliver a meaningful session on
subsection 55(2) and will include topics such as:
- understanding the “purpose” versus “results” tests;
- the computation of safe income and safe income dividend transactions;
- exceptions to the application of subsection 55(2) under paragraphs 55(3)(a) and 55(3)(b); and
- potential benefits arising from application of subsection 55(2) to certain dividends.
Kenneth Keung, CPA, CA, CPA (CO, USA), TEP, CFP, Moodys Tax, Calgary
John Schappert, CA, CPA, Moodys Tax, Calgary
|9:30 AM - 12:00 PM | WS-H | Room 522C [SOLD OUT]
|US Transfer Taxes
Sébastien Desmarais, Pryor Tax Law, Ottawa
Dean Smith, CPA, CA, TEP, CFP, Cadesky Tax, Toronto
|9:30 AM - 12:00 PM | WS-I | Room 523B
|Provincial Allocation and Reg 400 – does it deal with modern economy?
The rise of a modern economy has led to significant changes in industry trends, including an increasingly digitalized and service-oriented industry and has influenced the way corporate groups structure their business models and income generating apparatus. Unsurprisingly, the Canadian tax legislation has, to some extent, been late in properly addressing those changes.
Generally speaking, the existing Canadian provincial allocation rules seek to allocate corporate profits through the notion of “permanent establishment” using “gross revenue” and “salaries and wages” as proxies for the portion of taxable income that ought to be taxed in a given jurisdiction with the possible application of various deeming rules that may alter the resulting allocation. The purpose of this workshop is to revisit those rules in light of today’s modern and morphing economy. More specifically, as part of this session, we suggest an inquiry into the shortcomings and anomalous results that the existing provincial allocation rules for corporate profits may yield.
Among other things, as part of this session, will be addressed: the provincial allocation rules in the context of both modern and more traditional industries, the various deeming rules that may alter the provincial allocation of corporate profits, the impact of secondment and subcontracting agreements on provincial allocation, the notion of permanent establishment and the consequences of an erroneous or anomalous allocation of corporate profits.
Miguel Boissonneault, Deloitte LLP, Montreal
Thierry Morin-Cloutier, Deloitte Legal Canada LLP, Montreal
Geneviève Provost, CPA, CA, Deloitte LLP, Montreal