Canadian Tax Foundation 67th Annual Conference

Overview

The Canadian Tax Foundation’s 67^th Annual Conference is an industry-leading event, with over 1,000 attendees expected from Canada and abroad. Expert panels will cover corporate and international tax topics, and the conference hosts over 100 speakers, including the Hon. Justice Marshall Rothstein, Supreme Court of Canada. The conference’s three days of technical sessions take place at the Palais des congrès de Montréal.  The conference, which also offers opportunities to network, runs four streams of concurrent sessions, as well as plenary sessions on all three days. Extracurricular workshops offered on Sunday morning (November 22) require an additional registration fee.

Osler, Hoskin & Harcourt will host the Canadian Tax Foundation Conference’s Monday Night Reception, and three of Osler’s taxation partners will speak at conference sessions:

Marc Brender joins a panel of tax practitioners in a plenary session: Practitioners' Forum. The panel will discuss issues that small, medium and large taxpayers and their tax advisors encounter as they manage tax costs while complying with tax law in Canada and abroad:

• Technical
• Financial reporting
• Organizational and administrative  
• Compliance
• Audit and dispute resolution 

Manon Thivierge will speak at a concurrent session on Due Diligence Considerations in M&A Transactions, Including GST. Topics for discussion include:

• Identification of the purchaser’s and vendor’s principal tax concerns
• Use of representations, covenants and warranties
• Due diligence relating to foreign assets, elections and filing of forms
• Restrictive covenants
• Tax pools
• Transaction costs
• CCPC status

Richard Tremblay joins a panel to discuss Transfer Pricing—What Is/Are "Reasonable efforts"?  Should Penalties Always Apply? The penalty imposed under subsection 247(3) does not apply where a taxpayer has made reasonable efforts to determine arm’s-length transfer prices and to use those prices for purposes of the Act. Richard and his fellow panel members will explore the standard envisaged by the words “reasonable efforts” and provide examples of situations that do and do not meet the standard.

For more information, please refer to the conference programme.