Claire M. C. Kennedy, Bennett Jones LLP, Toronto
Sue Wooles, BMO Financial Group, Toronto
Conference Delegate List 2017 | Conference Program PDF
| Pre-Conference Session |
||
| POWERPOINT | YIN In-Depth: F/X Essentials Designed for YIN but all are welcome
• foreign-currency-denominated debt, • foreign affiliates, • the functional currency election, and • foreign exchange hedging. Moderator: YIN Rapporteur: Presenters |
|
| Agenda – Tuesday, April 25, 2017 | ||
| POWERPOINT
|
Multilateral Instrument/Treaty Update
This panel will consider various aspects of the OECD’s multilateral instrument (MLI), including with respect to • Intended scope and manner in which the MLI will impact existing bilateral tax treaties and the treaty negotiation process; • Various choices that countries may make in adopting the agreed BEPS “minimum standards”, as well as various alternative optional provisions;
Moderator: YIN Rapporteur: Ryan Walker, McCarthy Tétrault LLP, Toronto Presenters: Jesse F. Eggert, KPMG, Washington, DC Hersh Joshi, CA, CPA, Ontario Teachers’ Pension Plan, Toronto Stephanie Smith, Department of Finance, Ottawa Juan Carlos Trujillo Barroso, Deputy General Director of International Treaties, Ministry of Finance and Public Credit of Mexico |
|
| POWERPOINT
|
Evolution of Transfer Pricing Disputes
It has been almost 20 years since the enactment of section 247 and with it, the introduction of recharacterization, transfer pricing penalties and documentation requirements. Since then, there have been several significant operational, administrative and judicial developments which have both informed and impacted our collective experiences in managing, settling and, sometimes, litigating transfer pricing disputes. Through this retrospective lens, the panel will look back at some of the key developments since 1998 and then discuss and consider their impact on the current state of transfer pricing disputes and resolutions. We will also discuss related U.S. developments including the impact of arbitration under the Canada-U.S. Income Tax Convention. Moderator: Janice McCart, Blake, Cassels & Graydon LLP, Toronto YIN Rapporteur: Presenters: |
|
| POWERPOINT
|
Recent Canadian Developments
This panel will discuss recent Canadian developments in the international tax area, reviewing the relevant proposals in Budget 2017 and the September 16, 2016 draft technical bill, judicial developments with a particular focus on transfer pricing disputes, and recent Canada Revenue Agency interpretations. Moderator: Michael Kandev, Davies Ward Phillips & Vineberg LLP, Montreal
|
|
| POWERPOINT | International Tax Agenda Roundtable
This panel will discuss recent international tax developments in China, Ireland, the Netherlands, the European Union, the United Kingdom, and the United States, including responses to the OECD/G20 BEPS project, US tax reform proposals, the tax implications of Brexit, state aid, and the EU anti-tax avoidance directive. Moderator: Brian J. Arnold, Canadian Tax Foundation, London YIN Rapporteur: Presenters: |
|
| Agenda – Wednesday, April 26, 2017 | ||
| IFA Canada Annual General Meeting | ||
| IFA 2017 Congress Reports | ||
| International BEPS and Practical Consequences in Domestic and Multilateral Laws | ||
|
National Reporters: |
Hersh Joshi, Ontario Teachers’ Pension Plan Darren Hueppelsheuser, Norton Rose Fulbright LLP |
|
|
No PowerPoint |
The Future of Transfer Pricing | |
|
National Reporters: |
Jacques Bernier, Baker & McKenzie LLP Brad Rolph, Grant Thornton LLP |
|
| POWERPOINT | Tax Directors’ Roundtable: Pressing Topics from the Front Lines
Moderator: Brian Mustard, BCE Inc., Verdun YIN Rapporteur: Presenters: |
|
| POWERPOINT
|
Issues in Inbound & Outbound Collective Investing
This panel will review proposed US tax changes on structuring of carried interests, net interest deductions (planning for leverage) and moving intellectual property. Luxembourg Sarls have been a popular blocker for US funds investing in Canada and for double dip financing by Canadians buying businesses in US and in Europe. We will review the impact on treaty based holding companies (e.g. Luxembourg) of the proposed multilateral agreement, UK anti-hybrid rules, European anti-avoidance tax directive and any proposed legislative changes in Canada. We will have a case study on a US fund having US, foreign and tax exempt investors acquiring a Canadian operating company in the manufacturing business with operating subsidiaries in US, Spain, Italy, Mexico, India and China.
Moderator: Jack Bernstein, Aird & Berlis LLP, Toronto YIN Rapporteur: Presenters: |
|
| POWERPOINT | Select U.S. Legislative & Case Law Developments
This panel will discuss U.S. legislative and case law developments, including U.S. tax reform, U.S. tax cases and controversies and other U.S. developments of interest. Moderator: Alex Pankratz, Baker & McKenzie LLP, Toronto YIN Rapporteur: Presenters: |
|
| POWERPOINT
|
Finance Roundtable
Moderators: Carolle Fernando, McInnes Cooper, Halifax YIN Rapporteur: Presenters: |
|
| POWERPOINT
|
CRA Roundtable
CRA Response to the Roundtable* (Posted post-conference) Moderators: Byron Beswick, Felesky Flynn LLP, Calgary YIN Rapporteur: Presenters: |
|
ALBERTA:
For Alberta lawyers, consider including this course as a CPD learning activity in your mandatory annual Continuing Professional Development Plan as required by the Law Society of Alberta.
The Law Society of Alberta does not accredit courses offered by CLE providers nor assign hours to a course. It is the decision of each lawyer whether a CPD course or activity meets the requirements of Rule 67.1 and whether to include it in their CPD Plan.
BRITISH COLUMBIA:
This program has been approved by the Law Society of British Columbia for up to 11.5 CPD credits.
At the conclusion of the conference, you can click here to log-in to the Law Society of British Columbia’s website to register your credits. This program is listed under the name ‘2017 IFA International Tax Conference’.
MANITOBA:
This program may be reported for up to 11.5 hrs of eligible CPD activity.
The Law Society of Manitoba does not accredit providers, but will have the discretion to determine that activities offered by a specific provider are not eligible activities if they do not adequately promote competent practice. It is up to the lawyer to determine if the activity is an eligible CPD activity.
ONTARIO:
This program is eligible for up to 11.5 Substantive Hours.
According to the Law Society of Upper Canada, substantive hours may address substantive or procedural law topics and/or law related subjects that are relevant to the lawyer’s or paralegal’s practice and professional development.
QUEBEC:
Training activities held outside the Province of Québec and approved by another Canadian bar or foreign bar as part of a Mandatory Continuing Legal Education (MCLE) program of that other bar are automatically recognized by the Comité sur la formation continue obligatoire:
• regardless of whether or not the member of the Québec Bar is a member of that other bar, and;
• regardless of whether or not this training activity is offered by that bar itself or by a supplier accredited by that bar.
It is up to the member who wishes to attend such training activities to verify with the foreign bar that it is approved by under its own mandatory continuing legal education program and that it meets the requirements of the Règlement sur la formation continue obligatoire.
For these training activities, the member of the Québec Bar only has to declare in his training statement the training hours spent and to retain proof of registration and participation. No application for recognition shall be submitted to the Comité.
