7:15AM 
8:15AM

Registration and Breakfast

8:15AM
8:30AM

Opening Remarks

Heather L. Evans, TEP, Executive Director & CEO, Canadian Tax Foundation

8:30AM
9:20AM

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 2019.

Ameer Abdulla, CPA, CA, EY LLP, Waterloo 
Raj Juneja, McCarthy Tétrault LLP, Toronto

9:20AM
10:10AM

Current Cases

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

Chantal Copithorn, CPA, CA, PwC Canada LLP, Oakville
Timothy Fitzsimmons, PwC Law LLP, Toronto

10:10AM
10:20AM

Question/Answer Period

10:20AM
10:40AM

Refreshment Break

10:40AM
11:20AM

The Intersection of Trust Law and Tax Law

Taking a practical approach, this session will explore how trust law interacts with trust taxation and affects tax planning using trusts. 

M. Elena Hoffstein, Fasken, Toronto

11:20AM
12:10PM

Future of Surplus Stripping

Surplus stripping, a hotly debated topic, has again received an inordinate amount of attention recently.  The Department of Finance’s proposed anti-surplus stripping rules introduced in 2017 have concerned the tax community over the uncertainty and unintended tax consequences on the intergenerational passage of family businesses and distributions to shareholders of private corporations.  Although the proposed measures have been abandoned, taxpayers and their advisors can’t help but wonder what elements of surplus stripping would survive a review by the CRA.  Jurisprudence dealing with surplus stripping further reminds taxpayers that circumstances and perspective may play an important role in how the courts would rule on surplus stripping transactions. It is thus worth reviewing how surplus stripping works, what elements of surplus stripping causes the greatest amount of concern, and what that means to taxpayers and their advisors.  This session would focus on surplus extraction and will include a review of pipeline planning. 

Alexander Demner, Thorsteinssons LLP, Vancouver
Kyle Lamothe, Thorsteinssons LLP, Toronto

12:10PM
12:20PM

Question/Answer Period

12:20PM
2:20PM

Lunch

Luncheon speaker: 
Jamie Golombek, Managing Director, Tax and Estate Planning, CIBC, Toronto

2:20PM 
3:00PM

Compliance, Transparency and Tax Reporting

In recent years, both the amount and the complexity of tax reporting has grown considerably.  As a result, it is becoming increasingly more difficult and costly to be fully compliant with all of the tax reporting requirements for a business.  This session will discuss the changing landscape for tax compliance, as well as select tax reporting issues that tax practitioners and taxpayers need to be aware of.  Some of the issues covered will include the reporting of specified corporate income, select foreign reporting forms, and the reporting of intercorporate dividends.

Andrew Forbes, CPA, CA, KPMG LLP, Toronto
Dawn Munro, CPA, CA, KPMG LLP, Calgary

3:00PM
3:40PM

Transaction Due Diligence and Pre-deal Planning

This session will include a discussion of select issues related to pre-deal tax planning and structuring for the sale or acquisition of a business.  Tax and legal issues will be examined primarily from a vendor’s perspective, including structures and provisions to help minimize or defer taxes on sale, as well as certain constraints and considerations for the purchaser.  

Estelle Duez, LaBarge Weinstein LLP, Ottawa 
Stephen Rupnarain, CPA, CA, RSM Canada, Toronto

3:40PM
3:50PM

Question/Answer Period 

3:50PM
4:10PM

Refreshment Break

4:10PM
5:15PM

Case Study on Family Succession

This session will provide examples of how family businesses and their advisors can navigate conversations regarding succession planning, as well as taking into consideration relevant tax and non-tax issues that may need to be addressed.  This session will take a practical approach to understanding and mitigating tax risks in these situations, but also expand on other important factors that are critical to a successful transition plan.

Jag C. Gandhi, LL.B.,TEP, Miller Thomson LLP, Vaughan
Alexandra Spinner, CPA, CA, TEP, Crowe Soberman LLP, Toronto

5:15PM
5:25PM

Question/Answer Period

5:25PM
7:00PM

Networking Reception
If you’re feeling a little taxed after Monday’s sessions, we’ve arranged something special to help you unwind. Join us for appetizers and drinks in the foyer of Plaza ABC, for the chance to unwind and catch-up with colleagues.

7:30AM 
8:30AM

Registration and Breakfast

8:30AM
9:20AM

TOSI – A practical approach

Using practical examples, this session will provide an update on TOSI taking account of recent CRA interpretations. This session will also discuss the characterization of income and activity as it is relevant to TOSI such as whether income is business income or is from the provision of services.

Derek de Gannes, CPA, CA, RSM Canada, Toronto
Sankalp (Sunny) Jaggi, CPA, CA, CFF, RSM Canada, Toronto
Rishma Jessa, CGA, RSM Canada, Toronto 

9:20AM
10:10AM

Owner-Manager Renumeration and Selected Issues affecting Owner-Managers

This session will provide an update and discuss key factors to consider in developing a tax-effective strategy for the owner-manager in today’s environment under a variety of scenarios.  Topics will include the passive investment rules, clawback of the small business deduction (including the current state of integration with Ontario not aligning with the federal changes), and the overall tax cost of distributions from private corporations. 

Kevyn Nightingale, CPA, CA, TEP, MNP LLP, Toronto

10:10AM
10:20AM

Question/Answer Period

10:20AM
10:40AM

Refreshment Break

10:40AM
11:20AM

Issues in Crossing the Canada-US border for owner managers, their businesses and families

Businesses frequently expand across the Canada-US border, and with it follow the connections of families who own the businesses. This session will consider issues faced by Canadian owner-manager businesses expanding into the US, and by US owner-manager businesses expanding into Canada. The discussion will including structuring, remittance of retained earnings, issues with sending employees to work across the border, and common tips and traps. This session will also address some common issues faced by the owners of businesses as they emigrate from Canada to the US.

Debra Moses, CPA, BDO Canada LLP, Montreal
Jason Ubeika, CPA, CA, BDO Canada LLP, Mississauga

11:20AM
12:00PM

Taxable Canadian Property Issues

Taxable Canadian Property (TCP) is one of the fundamental concepts in Canada’s tax system.  A disposition of the TCP is one of the few ways by which non-residents would be subject to tax in Canada.  TCP has implications to persons resident in Canada in some circumstances as well.  In addition to the complex definition of TCP, the Income Tax Act also imposes onerous compliance procedures on transactions that involve TCP.   Unwary taxpayers can fall into one of the many traps in respect of TCP and suffer significant financial damages and aggravation.  This session will review the rules on the disposition of TCP, analyze the underlying polices, examine the anomalies and nuances, and discuss pitfalls and best practices in the context of TCP.   

Alexander Smith, Grant Thornton LLP, Toronto 
Jin Wen, CPA, CA, Grant Thornton LLP, Toronto 

12:00PM
12:10PM

Question/Answer Period

12:10PM
1:10PM

Lunch

1:10PM 
1:50PM

Effective Use of the Capital Dividend Account: An Update & Review

The CDA keeps track of various tax-free surpluses accumulated by a private corporation. These surpluses may be distributed tax-free in the form of capital dividends to the corporation’s Canadian-resident shareholders. Join us in this timely discussion on the requisite components of a CDA, important elections, trust distributions, eligible capital amounts, payments in kind and deemed dividend payments. 

David Stevens, Gowling WLG (Canada) LLP, Toronto 

1:50PM
2:30PM

Issues in Amalgamations

This presentation is an in-depth discussion through the use of case studies, the practical considerations associated with amalgamating corporations. Topics to be addressed include the different types of amalgamations (triangular, qualifying and short-form amalgamations), timing considerations associated with merging corporations (tax year-end, the effective date of amalgamations, and the acquisition of control rules), and rules respecting the new corporation and its shareholders (bumps, paid-up capital, debt settlement.)

Ron Choudhury, Miller Thomson LLP, Toronto
Michael Saxe, CPA, CA, MNP LLP, Markham 

2:30PM
2:40PM

Question/Answer Period 

2:40PM
3:00PM

Refreshment Break

3:00PM
3:50PM

Revisiting Taxpayer Relief and Ministerial Discretion

This session will include a discussion of the following:
 
• What is ministerial discretion and when does it apply?
• Scope of fairness relief under s. 220 and related rules
• How to challenge discretionary Ministerial decisions (second level administrative review and judicial review)
• Recent case law, e.g., ConocoPhillips (FCA), Bonnybrook (FCA), Revera Long Term Care (FC), Kerry Canada (FC) and Westminster Savings (FC)
• Trends & new possibilities

Panel Moderator: Martin Sorensen, Bennett Jones LLP, Toronto
Adam Scherer, CPA, CA, Crowe Soberman LLP, Toronto
Adrienne Woodyard, DLA Piper (Canada) LLP, Toronto 

3:50PM
4:40PM

CRA Audit Updates / Best Practices

Effectively managing tax audits is an important part of every taxpayer’s compliance activities, and assisting your clients to be most effective when responding to audits can pay dividends in making the process as smooth and efficient as possible.  Come learn from our distinguished panel of [senior CRA auditors] and tax advisors about current audit projects and areas of interest, hear best practices in managing the audit process, and get the inside scoop on tips, traps, and tales from the trenches to help you and your clients in the future.  Speakers will also be asked to give insights on how best to prepare for the audit, and how to resolve potential controversies at the audit stage.

Brandon Hodge, MNP LLP, Markham 
Mark Tonkovich, Blake, Cassels & Graydon LLP, Toronto 

4:40PM
4:50PM

4:50PM

Adjournment