7:30AM
8:30AM
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Registration and Breakfast
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Moderator: |
Amit Ummat, Ummat Tax Law, Burlington |
8:30AM
9:20AM
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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
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9:20AM
10:10AM
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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.
Katherine Fayolle, MNP LLP, Toronto
Kevyn Nightingale, CPA, CA, TEP, MNP LLP, Toronto
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10:10AM
10:20AM
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Question/Answer Period
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10:20AM
10:40AM
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Refreshment Break
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Moderator: |
Cheryl Bailey, Sun Life Financial, Toronto |
10:40AM
11:20AM
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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
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11:20AM
12:00PM
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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
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12:00PM
12:10PM
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Question/Answer Period
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12:10PM
1:10PM
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Lunch
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Moderator: |
Megan Seto, Deloitte LLP, Toronto |
1:10PM
1:50PM
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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
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1:50PM
2:30PM
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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
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2:30PM
2:40PM
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Question/Answer Period
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2:40PM
3:00PM
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Refreshment Break
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Moderator: |
Martin Sorensen, Bennett Jones LLP, Toronto |
3:00PM
3:50PM
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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
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3:50PM
4:40PM
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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 hear from our panel (including both senior CRA auditors and tax advisors) about the state of small and medium business audits, current areas of audit interest, and best practices in managing the audit process to help you and your clients. 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
Gilles Robert, Manager, Medium Business Audit, Small & Medium Enterprises Directorate, Canada Revenue Agency
Sharon Sicard, Manager, Small Business Audit, Small & Medium Enterprises Directorate, Canada Revenue Agency
Mark Tonkovich, Blake, Cassels & Graydon LLP, Toronto
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4:40PM
4:50PM
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Question/Answer Period
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4:50PM
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Adjournment
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