Wednesday, December 2, 2020
11:00 AM - 12:00 PM PST | 2:00 PM - 3:00 PM EST



This event is being hosted by the Toronto Young Practitioner Steering Committee
SESSION: Partnerships and Foreign Affiliates

Kristy Balkwill and Carl Deeprose will address a fundamental international tax issue in an unusual light: the application of the Canadian foreign affiliate regime to partnerships. The presentation will provide an overview of the foreign affiliate regime generally and the basics of partnerships and then explore the complications that arise when a cross-border corporate structure includes one or more partnerships, either as a Canadian partnership directly owning shares of foreign affiliates, or foreign partnerships. The presentation will provide a broad overview of these rules and consider specific issues such as the implications to FAPI, distributions from foreign affiliates to partnerships and recharacterization problems.

Kristy Balkwill, Manulife
Carl Deeprose, Norton Rose Fulbright Canada

Q&A: Questions will be addressed after the presentation, time permitting.



2:00 PM - 3:00 PM Eastern Standard Time
11:00 AM - 12:00 PM Pacific Standard Time
12:00 PM - 1:00 PM Mountain Standard Time
1:00 PM - 2:00 PM Central Standard Time
3:00 PM - 4:00 PM Atlantic Standard Time

These events are aimed at all those who have been practicing tax for ten years or less. All Young Practitioners are welcome; you do not have to be a member of the Canadian Tax Foundation to attend these events.  

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If you do not have a CTF log-in and would like to set one up to register for this event, please email and we can help. Please include your contact information (name, organization, address, phone, email, and tax practice start date.)

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Written notice of cancellation will be accepted until 12 noon ET on Wednesday, November 25, 2020.  Substitutions can be accommodated until Friday, November 27, 2020 at 12PM EST