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

The registration desk will open at 7:15 am on Monday, May 27th and will remain open for the duration of the conference. Please check in at the registration desk, located in the foyer of Crystal Ballroom at the Fairmont Palliser Hotel.

 The CTF EVENTS app is available for download in your App store! Search “CTF EVENTS” in your app store and download it today for access to all of the materials. You can access the desktop version here.

Monday, May 27, 2019

7:15am
8:15am
Registration and Breakfast
8:15am
8:30am
Opening Remarks

Heather L. Evans, Executive Director & CEO, Canadian Tax Foundation
Moderator: Siobhan A.M. Goguen, Felesky Flynn LLP, Calgary
8:30am
9:25am

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.

Richard Barnay, CA, PwC Canada LLP, Calgary
Patrick Lindsay, PwC Law LLP, Calgary

 9:25am
10:30am

Recent Court Decisions

A review of recent cases that affect owner-managed businesses and private companies.
This session will include a discussion of the following cases:

  • Plains Midstream Canada ULC v. R (FCA);
  • Deans Knight Income Corporation (TCC);
  • Cameco (FCA);
  • Saskatchewan Court of Appeal – Carbon Tax;
  • Quinn Estate;
  • Lee v. The Queen;
  • Laplante v. The Queen;
  • Jencal Holdings;
  • Pangea One;
  • Atlantic Packaging
  • Canada v. 594710

Jennifer Hanna, MNP LLP, Calgary
Sandra Mah, DLA Piper (Canada) LLP, Calgary

10:30am
10:40am

 Question/Answer Period

10:40am
11:00am

 Refreshment Break

 Moderator: Mark H. Woltersdorf, Dentons Canada LLP, Edmonton
11:00am
11:45am

Canadian Business Expansion into the US: Is the Grass Really Greener?

The overall objective of this presentation is to review what Canadian businesses investing in the US can expect with respect to US and Canadian tax implications. This presentation will cover various elements using a ‘case study’ for business investment inbound into the US highlighting implications from the Tax Cuts and Jobs Act (TCJA).

Karen Coil, CPA, EY LLP, Calgary
Mark Coleman, EY Law LLP, Calgary

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11:45am
12:25pm

US and Canadian Personal Tax Considerations When Moving Across the Border

In the wake of US tax reform, many Canadian small business owners are contemplating investments in the United States or relocating to the United States.  When does a relocation make sense, and for whom?  At the same time, US citizens who do business in Canada or who live in Canada must determine whether they should become or cease to be residents of Canada.  What are the benefits and costs to these US citizens of gaining or losing Canadian residence?

Marsha Dungog, Moodys Gartner Tax Law LLP, Calgary
Elan Harper, Moodys Gartner Tax Law LLP, Calgary

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12:25pm
12:40pm

 Question/Answer Period

12:40pm
2:00pm

 Lunch

Moderator:  Dylan Hughes, CPA, CA, MNP LLP, Calgary
2:00pm 
2:40pm

Purchase and Sale of a Business

This session will cover select tax issues arising in purchase and sale transactions that practitioners should know.  Issues to be covered include: considerations in the due diligence stage, planning for pre- or post-closing amalgamations following CRA comments on PUC reductions; structuring consideration terms; compensating key persons and restrictive covenants.


Colena Der, Osler, Hoskin & Harcourt LLP, Calgary
Corinne Grigoriu, Cassels Brock & Blackwell LLP, Calgary

2:40pm
3:20pm

Taxation of Farming

The Income Tax Act contains a number of relieving provisions that provide farmers with considerable latitude when planning for a transition - and yet, breaking up the family farm is hard to do!  Outsized land values when compared to other farm assets combined with a very strong emotional connection to the land make for difficult family and estate planning decisions when dealing with a family farm operation.  This session will review the intergenerational family farm rollover provisions as well as the capital gains deduction provisions for qualified farm property and highlight important nuances and differences in their application. The majority of the session will explore real life examples and provide practical strategies for practitioners, with a particular emphasis on strategies for splitting up the family farm in a tax efficient manner.  Estate planning considerations including the use of options on farmland will also be discussed.  

Jeremy J. Herbert, Felesky Flynn LLP, Edmonton
Jason Stephan, CA, TEP, CA Tax Law, Red Deer

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3:20pm
3:30pm

 Question/Answer Period 

3:30pm
3:50pm

 Refreshment Break

Moderator: Michael M. Ziesmann, MLT Aikins, Winnipeg
3:50pm
4:50pm

Anatomy of a Tax Dispute Understanding the CRA Audit and Objection Process

The focus of this presentation will be on disputes arising under the Income Tax Act and Excise Tax Act.


Dennis Auger, CPA, CA,
KPMG LLP, Calgary
Sophie Virji,
Bennett Jones LLP, Calgary

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4:50pm
5:00pm

 Question/Answer Period

5:00pm
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 the Crystal Ballroom, for the chance to unwind and catch-up with colleagues.

Program is subject to change. Please check back frequently for the most up-to-date version

Tuesday, May 28, 2019

7:30am
8:30am
Registration and Breakfast
Moderator: Kenneth Keung CA, CPA, Moodys Gartner Tax Law LLP, Calgary
8:30am
9:25am

An Overview of TOSI

This session will include a discussion on the following:

  • TOSI decision tree
  • TOSI key definitions
  • Summary of “excluded amounts” or “exceptions” for different age groups
  • Key exceptions to TOSI: Details/CRA’s Recent Views/Whether CRA’s interpretation consistent with the scheme of the Act.
  • GAAR considerations

Jessica Fabbro, Dentons Canada  LLP, Edmonton
Megan Ni, CPA, CA, KPMG LLP , Calgary

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 9:25am
10:20am

Planning in the Brave New World of TOSI

This session will include a discussion of the following:

  • TOSI overview (high-level)
  • Owner-manager remuneration planning
  • Tax planning for TOSI
  • Managing TOSI risk

Lesley Kim, Miller Thomson LLP, Regina
Shashi Malik, CPA, CA, TEP, Miller Thomson, Calgary

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10:20am
10:30am

 Question/Answer Period

10:30am
10:50am

 Refreshment Break

 Moderator: Nancy Diep, Blake, Cassels & Graydon LLP, Calgary  
10:50am
11:30am

Professional Corporations and Personal Service Businesses - Where are We Now?

The Canadian government seems to have sorted out its tax policy position on most aspects of professional corporations and personal services businesses. The government’s position, which appears to be supported by concerns over the substantial increase in the use of private corporations in recent years, has been accompanied by a host of legislative changes, which have reshaped the landscape of tax planning. This presentation and paper will bring you up to speed on recent legislative changes and CRA positions respecting professional corporations and personal services businesses.

Nick Kietaibl, CPA, CA, BDO Canada LLP, Red Deer
Jeremy Martenstyn, CPA, CA, BDO Canada LLP, Toronto

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11:30am
12:10pm

Reasonableness: Proceed at Your Peril

This session will:

  • provide a roadmap to move beyond “it depends on the facts and circumstances” response;
  • Assist in defining the facts and circumstances and assessing their impact on interest and dividends paid;
  • Focus on the private company situation where shareholders and their families have invested via debt or shares; and
  • Provide parameters to assist in assessing.


Michael Devonshire, CPA, CA, CBV, BDO Canada LLP, Calgary
Eric Wipf, CPA, CGA, TEP,
BDO Canada LLP, Calgary

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12:10pm
12:20pm

 Question/Answer Period

12:20pm
1:20pm

 Lunch

Moderator: Shaira Nanji, KPMG Law LLP, Calgary  
1:20pm 
2:00pm

Employee Stock Options and Other Equity-Based Incentives for Private Corporations

Implementing an equity-based incentive program for a private corporation raises unique issues.
This session will explore the following:

  • Making the decision between offering equity versus providing for phantom entitlements
  • Stock option plans for private corporations – how is the tax treatment different than for public corporations? 
  • Other equity plans for employees such as employee share purchase plans
  • The strengths and limitations of phantom plans and structuring such plans to avoid the salary deferral arrangement rules, including a review of RSUs and DSUs in the private company context

Brian Milne,
Norton Rose Fulbright Canada LLP, Calgary
2:00pm
2:50pm

Potpourri of Tax Administration Issues


Catherine Berry, Assistant Director, Income Tax Audit, Southern Alberta TSO,
Canada Revenue Agency, Calgary
George Hotson, Chief of Appeals, Southern Alberta TSO,
Canada Revenue Agency, Calgary
Anu Nijhawan,
Bennett Jones LLP, Calgary
Dean Radomsky,
EY LLP, Calgary

2:50pm
3:00pm

 Question/Answer Period 

3:00pm
3:30pm

 Refreshment Break

3:30pm
4:40pm

Anatomy of a Tax Court Appeal Trial - A Mock Trial Based on Gary Ritchie v. The Queen

If a taxpayer is not satisfied with the CRA's decision on her/his notice of objection, further recourse requires an appeal to the Tax Court of Canada.

This session will provide an overview of the typical pre-trial litigation steps for a taxpayer's appeal to the Tax Court, followed by "real time" conduct of a mock Tax Court trial hearing, which will include opening statements of legal counsel, examination-in-chief and cross-examination of a witness, introduction of documents into evidence, closing arguments, and delivery of an oral judgment from the Bench. The learning points from this mock trial should assist in "demystifying" a Tax Court appeal for non-lawyers, and should provide some practical guidance for any tax advisors who represent taxpayers in informal or general procedure appeals to the Tax Court.


Andrew Bateman,
Felesky Flynn LLP, Calgary
Dan Misutka, Felesky Flynn LLP, Calgary
Chris Saunders, Calgary
Ken Skingle, QC, Felesky Flynn LLP, Calgary
James Yaskowich, Felesky Flynn LLP, Edmonton

4:40pm
4:50pm

 Question/Answer Period

4:50pm

 Adjournment

Program is subject to change. Please check back frequently for the most up-to-date version

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