2017 Conference

We’re excited that 2017 IFA International Tax Conference is fast approaching. Get ready by reviewing sessions and saving them to your personal agenda. Bookmark the app to your homescreen for instant access to all the information you need to have a great event experience!
The Conference will be held in Toronto at the Metro Toronto Convention Centre (North Building) in the heart of the business and financial district on 255 Front Street West. The focus of the program will be international tax issues that are impacted by international cross border transactions.



Claire M. C. Kennedy, Bennett Jones LLP, Toronto
Sue Wooles, BMO Financial Group, Toronto

Agenda – Tuesday, April 25, 2017




Breakfast | Registration Desk Opens


Sponsored by:


Pre-Conference Session


YIN Welcome

















YIN Rapporteur:



YIN In-Depth: F/X Essentials

Designed for YIN but all are welcome

This session will provide a foundational overview of foreign exchange issues arising under the Income Tax Act, including with respect to

• foreign-currency-denominated debt,

• foreign affiliates,

• the functional currency election, and

• foreign exchange hedging.


Ryan Rabinovitch
, McCarthy Tétrault LLP, Montreal

Christopher Sheridan, Osler, Hoskin & Harcourt LLP, Toronto

Chris Anderson, Davies Ward Phillips & Vineberg LLP, Toronto
Erin Foote, Deloitte LLP, Toronto
Ilia Korkh, EY Law LLP, Vancouver
Phil Ward, Bennett Jones LLP, Toronto






Conference Registration | Refreshment Break


Sponsored by:



Conference Welcome & Opening Remarks






















YIN Rapporteur:



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;

• Timing and process leading to the MLI’s provisions coming into force in particular countries;

• Impact of countries signing (or not signing) the MLI – including where different choices are made;

• Approach and scope to binding arbitration; and

• Anticipated next steps – for countries and taxpayers (with a focus on Canada, the United States and Mexico).


Patrick Marley
, Osler, Hoskin & Harcourt LLP, Toronto


Ryan Walker, McCarthy Tétrault LLP, Toronto


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


Sponsored by:














YIN Rapporteur:



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.


Janice McCart, Blake, Cassels & Graydon LLP, Toronto

Amanda Heale
, Osler, Hoskin & Harcourt LLP, Toronto

Phil Fortier
, Deloitte LLP, Toronto
Alexandra MacLean
, Canada Revenue Agency, Ottawa
David Rosenbloom
, Caplin & Drysdale, Washington, DC
John J. Tobin
, Torys LLP, Toronto





Tribute to Brian Arnold

Keynote Address

With special guest speaker


Janice Gross Stein, Belzberg Professor of Conflict Management in the Department of Political Science and the Founding Director of the Munk School of Global Affairs at the University of Toronto

Sponsored by:











YIN Rapporteur:



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.



Michael Kandev, Davies Ward Phillips & Vineberg LLP, Montreal

Audrey Dubois
, KPMG LLP, Montreal

Carrie Smit
, Goodmans LLP, Toronto
Kim Maguire
, Borden Ladner Gervais LLP, Vancouver
Christopher Steeves
, Fasken Martineau DuMoulin LLP, Toronto
Julie Vezina
, PricewaterhouseCoopers LLP, Montreal




Refreshment Break


Sponsored by:










YIN Rapporteur:



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.


Brian J. Arnold, Canadian Tax Foundation, London

Lindsay Gwyer
, Stikeman Elliott LLP, Toronto

Wei Cui
, University of British Columbia, Vancouver
Marja de Best
, Loyens & Loeff N.V., Rotterdam
Ray O’Connor
, Ernst & Young LLP, Dublin
David Rosenbloom
, Caplin & Drysdale, Washington, DC
Dominic Stuttaford
, Norton Rose Fulbright LLP, London







Cocktail Reception

Toronto Centre Intercontinental Hotel | Ballroom
225 Front Street West | «Get Directions»





Toronto Centre Intercontinental Hotel | Ballroom


Sponsored by:




YIN After Party – Scaddabush | 200 Front Street West | Directions


Sponsored by:



Agenda – Wednesday, April 26, 2017



Registration & Breakfast


IFA Canada Annual General Meeting


IFA 2017 Congress Reports

Subject 1:


International BEPS and Practical Consequences in Domestic and Multilateral Laws

National Reporters:


Hersh Joshi, OTPP
Darren Hueppelsheuser, Norton Rose Fulbright

Subject 2:


The Future of Transfer Pricing

National Reporters:


Jacques Bernier, Baker & McKenzie
Brad Rolph, Grant Thornton LLP





YIN Rapporteur:



Tax Directors’ Roundtable: Pressing Topics from the Front Lines



Brian Mustard, BCE Inc., Verdun


Clara Pham, Restaurant Brands International, Toronto


Marie Blanchard, SNC-Lavalin Inc., Montreal
Marc Desrosiers
, Thomson Reuters, New York
Carolyn Mulder
, Wal-Mart Canada Corp., Mississauga
Douglas J. Powrie
, Teck Resources Ltd., Vancouver
Sue Wooles
, BMO Financial Group, Toronto



Refreshment Break

Sponsored by:
















YIN Rapporteur:



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.

We will have a second case study involving a Canadian fund and a Canadian Pension acquiring a US business. We may also deal with US planning where two Canadian pensions are purchasing a large portfolio of US rental properties and to avoid US FIRPTA on a sale.


Jack Bernstein, Aird & Berlis LLP, Toronto

Saam Nainifard
, Aird & Berlis LLP, Toronto

Raffaele Gargiulo
, Van Campen Liem, Luxembourg
John Lorito
, Stikeman Elliott LLP, Toronto
Paul Stepak
, Blake, Cassels & Graydon LLP, Toronto
Ron G. Nardini
, Akin Gump Strauss Hauer & Feld LLP, New York



Buffet Lunch








YIN Rapporteur:



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.



Alex Pankratz, Baker & McKenzie LLP, Toronto

John Lennard
, Davies Ward Phillips & Vineberg LLP, Toronto

J. William Dantzler
, White & Case LLP, New York
Andrius Kontrimas
, Norton Rose Fulbright US LLP, Houston
Paul Seraganian
, Osler, Hoskin & Harcourt LLP, New York







YIN Rapporteur:



Finance Roundtable



Carolle Fernando, McInnes Cooper, Halifax
Ken Buttenham
, PricewaterhouseCoopers LLP, Toronto

Sam Kwok
, Ernst & Young LLP, Toronto

Stephanie Smith
, Department of Finance, Ottawa
Ted Cook
, Department of Finance, Ottawa



Refreshment Break






YIN Rapporteur:



CRA Roundtable



Byron Beswick, Felesky Flynn LLP, Calgary
Heather O’Hagan
, KPMG LLP, Toronto

Sarah Chiu
, Felesky Flynn LLP, Calgary

Dave Beaulne
, Canada Revenue Agency, Ottawa
Lori Carruthers
, Canada Revenue Agency, Ottawa




Delegate Pen Sponsor

WIFI Sponsor


Charging Station Sponsor

Registration Fees

Online registration is now closed. Please register onsite.

The registration desk is located in front of the Plenary Room 205, in the North Building of the MTCC on street level.

HST (13%) will apply to all registration fees

On or Before April 7

Beginning April 8

IFA Member



Young Member1












Special Offer2



Special Offer – Young Member 1,2



Registration includes access to all Sessions, Electronic Materials, 2 continental breakfasts, 2 luncheons and Tuesday cocktail/dinner + YIN After Party.

1 Young Member: Valid for members 29 years of age and under for the current membership year. Please provide DOB.

2 Special Offer: New IFA Canada Members Only: Discounted 2017 IFA Membership plus Member rate for Seminar

IMPORTANT: Your registration includes 1 Ticket for the Tuesday, April 25, 2017 dinner and access to the YIN After Party following the dinner. Please make sure you RSVP as part of your registration if you intend to attend these events.



(Electronic materials will be available to all attendees via the App)



Additional Dinner Tickets
(We must have guest names in advance)





IFA Canada has reserved a block of rooms at the Intercontinental Toronto Hotel for out-of-town registrants and locals wishing to stay at the conference site. Please be sure to ask for the International Fiscal Association rate and book before Monday, April 3, 2017. Delegates should make their own hotel arrangements by calling the hotel directly or booking online via the below reservations link.

Call 1-800-235-4670 to make your reservations.

Intercontinental Toronto Hotel
225 Front Street West
Toronto, ON M5V 2X3

Get Directions

single/double – $199



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.

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’.

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.

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.

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.