Ontario Tax Conference

Keeping Tax Practitioners Informed

Monday and Tuesday, October 24 & 25, 2011

The Doubletree Hotel
655 Dixon Road, Toronto

[Fees] [Cancellation]
[Program Committee]
[Hotel Accommodation]

Register online
***Please register on-site Monday morning***
Registration opens at 7:30 am

Early Bird deadline is Friday, September 30, 2011

Renew your acquaintances, create new alliances with other tax professionals and government officials, and benefit from great networking opportunities.

Monday, October 24, 2011
7:30 am  Registration opens 
7:30 am 

Sponsored by


8:15 am  Opening Remarks

Larry Chapman - Executive Director and CEO, Canadian Tax Foundation 
8:30 am - 9:20 am Current Issues

This session will review recent legislative and administrative developments in federal and provincial tax law including
  • Aggressive Tax Planning Disclosure
  • Federal Budget Changes
    • New credits
    • RSP/RRSP/RDSP changes
    • IPP
    • Kiddie tax
    • Flow through shares
    • Charity changes
    • Mutual fund trust changes
  • EPSPs
  • Provincial Budget Update
Joan Jung - Minden Gross (Toronto)
Stella Gasparro, CA - Meyers Norris Penny (Toronto)
9:20 am - 9:55 am Current Cases

A review of recent decisions from the Tax Court, the Federal Court of Appeal and the Supreme Court that impact owner-managed business and private companies

Paul Bleiwas - Fraser Milner Casgrain LLP (Toronto)
Alexandra Brown - Laishley Reed LLP (Toronto)

9:55 am - 10:10 am Questions
10:10 am - 10:30 am
Refreshment break

Sponsored by
Minden Gross

10:30 am - 11:10 am Directors' Liability

Sunita Doobay - TaxChambers (Toronto)
Joseph Markson - Markson Law (Toronto)

11:10 am - 11:45 am

CRA's Reach for Information

How broad is the scope of CRA powers to obtain domestic and foreign-based information for income tax and GST purposes? Does it end after the tax audit?

  • Resisting the reach: What are some limits on the exercise of CRA powers (relevance, legal privilege, non-compliance with procedural safeguards, the Charter)?
  • Demands for third party information from accountants-what crosses the line?
  • How do you formally contest seemingly abusive/illegal requests/demands for information?
  • Facing the increased threat by CRA to seek compliance orders- what are the practical ways to handle this?
  • Is there a legal right to resist the provision of information/documents relating to periods beyond the normal reassessment period?
  • In what circumstances is CRA entitled to reassess beyond the normal reassessment period?
  • Books and records: What qualifies and what does not for statutory purposes? 

Ed Kroft, Q.C. - Blake, Cassels & Graydon (Vancouver)

11:45 am - 12:00 pm Questions
12:00 pm - 2:00 pm

Luncheon Speaker:

Richard Loreto, Ph.D.

Applying Demographics to Business Strategy
 Richard is the president of R.A.L. Consulting Limited, a management-consulting firm based in Hamilton, ON and has advised both private and public sector organizations on the cost-effective development of business strategy. He is an acknowledged leader in the use of demographic analysis to manage the issues impacting a client’s products or services, work force, or marketing approaches as a result of the aging and increasing diversity of the population in Canada and the United States.
Sponsored by
Thorsteinssons LLP

2:00 pm -2:35 pm Estate Planning - Pipeline Strategy and other post-mortem planning strategies

Rob Martini and Gwen Benjamin - Wilson Vukelich (Toronto)

2:35 pm -
3:10 pm 
Estate Planning - Trusts and Estate Planning for US Beneficiaries (including an update on the US Estate Tax) 

This presentation will examine the complications introduced to a Canadian estate plan where the beneficiaries of such a plan include US citizens and/or residents.  The impact on such common strategies as an estate freeze and the issues presented by Canadian trusts and holding corporations will be canvassed, with reference to the following statutory regimes:

  • US transfer tax considerations
  • US income tax considerations
  • Compliance and reporting obligations
  • Canadian income tax issues

Heather Evans - Deloitte (Toronto)
Robert L. Dumont - Deloitte Tax (New York)

3:10 pm -3:25 pm Questions
3:25 pm - 3:45 pm
Refreshment break
3:45 pm -4:20 pm Estate Planning - Wills and non-tax issues relating to estate planning

Suzana Popovic-Montag - Hull & Hull LLP (Toronto)
Ian M. Hull - Hull & Hull LLP (Toronto)

4:20 pm -4:55 pm  Estate Planning - Litigation arising out of estate planning 

Kimberly Whaley - Whaley Estate Litigation (Toronto)
4:55 pm -5:00 pm Questions
5:00 pm Adjournment
5:00 pm -7:00 pm  Evening Reception


Tuesday, October 25, 2011
8:30 am - 9:20 am Partnerships Update

1) The New Proposed Partnership Anti-Deferral Rules

  • Background
  • Overview of proposed rules
  • Potential anomalies and issues with the proposed anti-deferral rules.  This section will canvas publicly available submissions to the department of finance as well as KPMG internally identified matters.

2) Case Law Update

  • 103(1) – Stow;
  • Partnership Freeze Case (Kato Kraus)

3) Partnerships in an International Context

  • CRA views relating to application of the 5th Protocol of the Canada-U.S. Treaty
  • CRA view on partnerships and paragraph 212(1)(b)
  • Partnerships and the Foreign Affiliate Rules

Samuel J. Tyler - Moskowitz + Meredith/KPMG (Toronto)
Steven Hurowitz - KPMG (Toronto)

9:20 am - 9:55 am

Owner-Manager Remuneration Update

This session will provide an update on the integration of the ever-changing tax rates as are applicable to individuals, corporations, and trusts in Ontario. The synthesis of these rates is then applied to the concept of integration in order to see how these tax rates can affect taxpayers’ decisions on how and through which kind of vehicle to earn income.

Franco Hasou, CA - Ernst & Young (Toronto)

9:55 am - 10:10 am Questions
10:10 am - 10:30 am

Refreshment break

10:30 am - 11:45 am Purchase and Sale of a Business

Mark Jadd - Heenan Blaikie (Toronto)
Eoin Brady, CA, PricewaterhouseCoopers LLP (Toronto)
11:45 am - 12:00 pm Questions
12:00 pm - 1:15 pm Luncheon
1:15 pm - 1:50 pm Sweating the Small Stuff: Avoiding Professional Practice Issues

Robin MacKnight - Wilson Vukelich (Toronto)
Allen Church - Evans Martin (Brampton)
1:50 pm - 2:25 pm

HST Update

  • Issues re: New HST Place of Supply Rules
  • Application/Complications re: Asset Purchase Transactions
  • Reimbursements, Taxable Supplies and Agency
  •  Government Payments: Grants/Subsidies vs. HST Taxable Supplies
  • “Retroactive” Registration and ITC Entitlement Issues
  • VDP Developments / Possible Concerns

Jack Millar - Millar Kreklewetz (Toronto)

2:25 pm -2:40 pm Questions
2:40 pm - 3:00 pm Refreshment break
Sponsored by

3:00 pm -4:15 pm Tax Administration Panel

A panel of representatives from the Canada Revenue Agency offices in Toronto and Ottawa will provide updates on recent interpretive, administrative and compliance developments relevant to small and medium-sized businesses.

James Hutchinson - Miller Thomson (Toronto)
Bruce Ball - BDO Canada (Toronto)
Vince Pranjivan - Deputy Assistant Commissioner, Ontario Region
Randy Hewlett - Interim Director, International Division, Income Tax Rulings Directorate, Legislative Policy and Regulatory Affairs Branch

4:15 pm - 4:30 pm Questions
4:45 pm Adjournment

Program Printing

Sponsored by
 Friedlan Law Harris & Chong LLP 
 Conference Binder

Sponsored by
Miller Thomson LLP

Program Committee
Don Carson
PricewaterhouseCoopers LLP
Ruth Cummings
Timothy Fitzsimmons
Philip Friedlan
Friedlan Law
Sandy Hale-Malhinha
BDO Dunwoody LLP
James Hutchinson
Miller Thomson LLP
Mark Jadd
Heenan Blaikie LLP
John Loukidelis
Simpson Wigle
Robin MacKnight
Wilson Vukelich LLP

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   Member Non-member*
Early Bird 
(register and pay on or before September 30)
$680 N/A
Regular (after September 30) $795 $1120
Government  $630  $780
Young Practitioner  $530 $680
Full-time Academic  $125 $125
Full-time Student  $100  $100 
Important note:
Each registration is intended for use by only one individual. Sharing a single registration between two or more individuals is not permitted.

* A reduced rate to conferences is only one of the benefits of a Foundation membership. Become a member today. 
Conference Materials**  
Conference Binder  $50.00 
Electronic   $0.00
** Important note about Conference Materials:

Conference Materials (papers and powerpoint presentations) will be posted on the CTF website prior to the conference. The conference registration fee includes electronic access to these materials; the registration fee does not include a printed copy of the materials.

If you would like to receive a Conference Binder, please select this option when registering; you will be charged an additional $50.00 to cover the cost of the binder.

Hotel Accommodation

Out-of-town registrants should make their own hotel reservations directly with the Doubletree Hotel. The hotel is holding a block of rooms for registrants on a first-come, first-served basis until Friday, September 23, 2011, after which they will be released. To access the special hotel rate negotiated for this event, please call the hotel at 1.800.668.3656 and identify yourself as a member of the Ontario Tax Conference, or book your accommodation online.

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If the originally registered individual is unable to attend the conference, registration may be transferred to one other individual. The name of the substituted delegate can be submitted to the Foundation's Toronto office up to three business days prior to the start of the conference. After that, the substitution will be accepted when the conference registration desk opens at the conference site. If substitution is not an option, written notice of cancellation will be accepted by the Conference Department at the Foundation's Toronto office until 5:00 pm EST on Friday, October 14, 2011. Individuals who cancel their registration prior to this deadline will receive a refund, less a $100 administration fee, at the conclusion of the conference. We regret that we can not issue refunds for notices of cancellation received after this deadline.