Sobey School of Business | Saint Mary's University | 923 Robie Street | Halifax
Friday, November 1, 2019
8:30 am - 9:30 am
Workshop Registration Desk Opens & Breakfast

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12:00 pm - 12:45 pm
Main Conference Registration Desk Opens & Lunch
PLENARY SESSION
12:45 pm - 1:00 pm

Opening Remarks

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

 1:00 pm - 2:30 pm
Current Issues Forum

This session will cover:
  • Recent court decisions that impact owner-managed businesses
  • Legislative and administrative developments, including technical interpretations and Folio updates issued by CRA in 2019
  • Investment tax credits and tax incentives
Moderator: TBA
Speakers:
Danielle Desjardins, CPA, CA,
PwC Canada, Halifax
Jennifer J. Hamilton Upham, Patterson Law, Truro
Greg MacDonald, Grant Thornton LLP, Halifax

2:30 pm - 2:40 pm
Questions
2:40 pm - 3:00 pm
Refreshment Break
CONCURRENT SESSIONS
3:00 pm - 4:00 pm
3:00 pm - 4:00 pm
Succession Planning/ Purchase and Sale of a Business

Over the years there have been numerous presentations that have dealt with common tax issues related to the purchase, sale or succession of a business. Rather that discussing those issues again, this presentation will focus more on the non-tax issues that can have an impact on these types of transactions. There will also be a portion of the presentation that will specifically address these considerations for a family business.

Moderator: Nathalie Amirault, CPA, CA, TEP, Grant Thornton LLP, Halifax

Speaker:
Adam Bata,
Stewart McKelvey, Halifax  
Reviewing Active vs. Passive Income

Since the decision in Smith v. Anderson in 1880, there has been a rebuttable presumption that income earned by a corporation is income from a business. This session will provide a comprehensive review of the application of the presumption by the courts and the Canada Revenue Agency. The specified investment business rules and how those rules may have impacted our analysis will also be considered. Finally, the presentation will review sections of the Income Tax Act that only apply when a corporation has a business or is earning income from a business, including subsection 84(2) and the tax on split income rules.

Moderator: TBA

Speakers: 
Andrew Plant, CPA, CA, Grant Thornton LLP, Halifax
C. Jennifer Talbot, Patterson Law, Halifax
4:00 pm - 4:10 pm  4:00 pm - 4:10 pm  
Questions   Questions
PLENARY SESSION
4:10 pm - 4:55 pm

TOSI – Things You Need to Know That You Didn’t Know You Needed to Know
 
Department of Finance drafted very subjective and complex legislation to deal with income splitting through private corporations, which they then punted the administration of these rules to CRA. We are now almost two years into the TOSI rules and what have we learned? This session will provide insight into the many comments, technical interpretations and guidance that has been provided both from the government and the professional community. In this session, it is assumed that the attendee already understands the basic mechanics of the rules, as we will be diving into various subjective and practical matters related to the actual administration of the rules. Be prepared to discuss and debate varying interpretations of subjective and ambiguous legislation and help come up with practical solutions to manage the associated risks.

Moderator: TBA

Speaker:
Jason Conrad, CPA, CA, AC Belliveau Veinotte Inc., Halifax

4:55 pm - 5:00 pm 
Questions 
5:00 pm - 5:45 pm
Senior Practitioners Roundtable

Speakers:
Jeffrey Blucher, TEP, McInnes Cooper, Halifax
Jim Cruickshank, Stewart McKelvey, Halifax
Ruth March, CPA, CA, TEP, KPMG LLP, Halifax

5:45 pm - 7:45 pm
Networking Reception
Time to relax and catch up with your fellow conference attendees. Join us for appetizers and drinks.

Saturday, November 2, 2019
7:30 am - 8:30 am
Breakfast 
PLENARY SESSION
8:30 am - 9:20 am
Tax Planning in Today's World

Tax planning for owner-managers has been significantly curtailed in the past few years, causing advisors to have to be more creative in planning transactions and plans that provide financial benefit to their clients. This presentation will explore some of the more notable transactions, including:

  • Prescribed Interest Transactions, including the “Half-Loaf” Transaction; and
  • Surplus Stripping
Moderator: TBA

Speakers: 
R. Daren Baxter, QC, TEP, McInnes Cooper, Halifax
Christopher Britton, CPA, CA, Martello Wealth Advisory Inc., Halifax

9:20 am - 9:30 pm 
Questions
CONCURRENT SESSIONS
9:40 am - 10:40 am
9:40 am - 10:40 am
An Update on the Associated Corporation Rules

As any tax practitioner will know only too well, the Income Tax Act contains expansive and complex provisions (referred to by some authors as the “relational rules”) that can result in significant and often unanticipated consequences when two or more entities are found to be related, affiliated or associated.  This presentation will review the implications of associated corporation status, briefly compare and contrast the associated corporation provisions with other relational rules, and provide an overview of the provisions governing the determination of associated corporation status among two or more corporate entities, with a particular focus on commonly encountered scenarios.  The presentation will also examine strategies for terminating associated corporation status, including a consideration of whether such techniques might run afoul of the GAAR.

Moderator: TBA

Speakers: 
P. Robert Arkin,
Cox & Palmer, Halifax
Earl MacLeod, CPA, CA, MNP LLP, Dartmouth

Doing Business in the Digital Age

Probably everyone has said that the world is a small place at one point in their life.  Never has that been truer than in the online world.  E-commerce has completed changed the landscape where at one time a business located itself in major centres so that it could access products, services and customers in order to thrive.   Now it is increasing the norm that a business can locate itself in small-town Canada and sell it products and services to the world without many restrictions.  This new model has placed strain on taxing authorities in countries (and their states/provinces and local governments) because a tax system designed around permanent establishments may no longer be relevant to keep up and collect the taxes that they feel should be levied on these e-businesses transacting with their citizens.  This presentation will focus on the new measures that have been introduced within North America and around the world that are designed to focus specifically on e-commerce.  Specific attention will be given to the Wayfair decision, measures announced by Quebec and Saskatchewan, and announcements coming out of the UK and the EU.


Moderator: TBA

Speakers:
Jeremy Scott, BDO Canada LLP, Halifax
Darlene Shaw, CPA, CA, CPA(IL), TEP, Baker Tilly Nova Scotia Inc., Dartmouth
10:40 am - 10:55 am  10:40 am - 10:55 am 
Questions  Questions 
10:55 am - 11:15 am
 Refreshment Break
PLENARY SESSION
11:15 am - 12:15 pm

Trust & Estate Planning

This session will provide an update on various estate planning topics, with particular emphasis on alter ego and joint partner trusts.  This will include a review of many technical and practical issues relating to alter ego and joint partner trusts.  A refresher on planning for the 21-year deemed disposition rule will be provided, and the relevance of trusts in the context of TOSI will be considered.

Moderator: Jeffrey Blucher, TEP, McInnes Cooper, Halifax

Speakers:
Nathalie Amirault, CPA, CA, TEP,
Grant Thornton LLP, Halifax
Catherine D.A. Watson Coles, QC, TEP,
McInnes Cooper, Halifax

12:15 pm -  12:30 pm
Questions 
12:30 pm
Adjournment

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