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
10:20am

Recent Court Decisions

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

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

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10:20am
10:30am

 Question/Answer Period

10:30am
10:50am

 Refreshment Break

10:50am
11:35am

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

The overall objective of this presentation is to review what Canadians 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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11:35am
12:15pm

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 or not 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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12:15pm
12:30pm

 Question/Answer Period

12:30pm
2:00pm

 Lunch

2:00pm 
2:40pm

Purchase and Sale of a Business

This session will cover select tax issues practitioners should know.  Issues to be covered include: a discussion on safe income and modelling considerations in the context of CRA’s Roundtable discussion at the 2018 annual conference; section 84.1 and non-arm’s length transfers; anti-avoidance sections 110.6 (7), (8) & (9); stated capital reduction prior to amalgamation; employee buycos; and capital gains on the seller side. 

Colena Der, Osler, Hoskin & Harcourt LLP, Calgary
Corinne Grigoriu, Osler, Hoskin & Harcourt 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

3:50pm
4:50pm

Anatomy of a Tax Dispute [up to and including the Notice of Objection

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


Dennis Auger, 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

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

10:20am
10:30am

 Question/Answer Period

10:30am
10:50am

 Refreshment Break

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 is 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

1:20pm 
2:00pm

Canada’s Taxation Regime Involving Employee Stock Option Benefits

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

Anu Nijhawan,
Bennett Jones LLP, Calgary
Dean Radomsky,
EY LLP, Calgary

2:50pm
3:00pm

 Question/Answer Period 

3:00pm
3:20pm

 Refreshment Break

3:20pm
4:30pm

Anatomy of a Tax Court Appeal

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

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4:30pm
4:40pm

 Question/Answer Period

4:40pm

 Adjournment

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

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