Overview
The CTF’s 70th Annual Tax Conference takes place at the Vancouver Convention Centre from Sunday, November 25th to Tuesday, November 27st, 2018. Members of Osler’s Tax practice will be speaking on various panels and leading workshops. Osler is also proud to sponsor the Monday evening networking reception. For more details on the reception, please click here.
US Tax Reform
Almost one year later, how has U.S. tax reform affected Canadian multinationals? Who are the winners and who are the losers? This session will explore certain aspects of tax reform and how they have affected, and will continue to guide, the way Canadian multinationals manage their tax burdens. The pitfalls, uncertainties, and opportunities created by this milestone reform will be explored – specifically, those related to interest expense limitation, hybrid provisions, the BEAT, and FDII.
Speaker: Paul Seraganian
Foreign Affiliate Update: Issues with Non-Corporate Vehicles
This session will be a review of selected technical and practical issues that can arise under the foreign affiliate and surplus rules when a vehicle other than a “standard” corporation (such as a non-traditional corporation, a partnership or a trust) is located within a foreign affiliate structure that is ultimately owned by a Canadian-resident corporation. This review will include on overview of recent entity classification developments, recent amendments on corporations without share capital (section 93.2), hybrid entity issues (including US LLCs), issues with partnerships and foreign affiliates, trusts (in general and including sections 94, 94.2 and 93.3).
Speaker: Drew Morier
Understanding and Doing Business with Tax-Exempt Entities
Investment-orientated tax exempt entities (“TEEs”) such as pension funds play a significant role in the Canadian economy. Increasingly, Canadian businesses of various sizes are looking to TEEs as a critical source of financing and investment. Issues that will be covered in this session will include how TEE’s status under the Income Tax Act (and the desire to preserve such status) may impact planning and structuring considerations when advising on a proposed investment or financing. The importance to TEEs of adhering to non-tax legislative or regulatory requirements when making investment will also be considered. The session will also review potential limits on tax exempt status including the application of GST, Part XIII of the Income Tax Act and penalty provisions. The purpose of the session will be to provide insight to both practitioners who regularly work directly with TEEs and practitioners who have clients that may have dealing with TEEs.
Speaker: Jack Silverson
(Can’t Get No) Satisfaction?: Take a Look Beyond the ‘Fairness Provisions’
This section highlights some of the alternative means of obtaining “satisfaction” beyond the typical “taxpayer relief” provisions of the Income Tax Act. While the latter have had more playtime over the years (and are the subject of many more decisions of the Federal Courts), there are some real indy hits out there that should be added to your playlist.
Panelist: David Jacyk