Co-Lecturers:
Angelo Nikolakakis, EY Law LLP * / Ernst & Young LLP **, Montreal
Robert Raizenne, Osler, Hoskin & Harcourt LLP, Montreal
(* Affiliated with Ernst & Young LLP in Canada. ** Angelo Nikolakakis is not a partner of Ernst & Young LLP, but a limited partner of Ernst & Young L.P. which provides services to Ernst & Young LLP)
The Lecture, designed to be of interest to a broad range of seasoned practitioners, beginners, academics, policy makers, and other decision makers, will provide a detailed review of the numerous transfer pricing and other analogous rules and principles applicable under the Canadian federal Income Tax Act, as well as their judicial and administrative interpretation, including an examination of the various pricing methodologies and profit level indicators typically used in practice, with a view to promoting a solid understanding of these matters and identifying any differences in the outcomes they may produce.
The Lecture will set the stage for this discussion with an overview of the historical development of these principles and practices, both in Canada and internationally, as well as a comparison of the application of the arm’s length principle with other approaches to income allocation and taxation, including approaches currently being considered by the new administration in the United States. The Lecture will also feature a discussion of important current developments and practical implications arising in connection with the OECD’s BEPS initiative, including revisions to the Transfer Pricing Guidelines in relation to risk, capital, intangibles, and safe harbours, as well as European Union State Aid controversies. The Lecture will not focus on transfer pricing documentation issues.
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07:30-08:30 |
Registration and Refreshments |
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8:30-12:30 |
Lectureship: The Theory and Practice of Transfer Pricing: Past, Present and Future |
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OTTAWA Registrations closed |
Wednesday, January 25, 2017
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Venue: Courtyard by Marriott Ottawa Downtown | 350 Dalhousie Street Meeting Room: Laurier
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MONTREAL Registrations closed |
Tuesday, January 31, 2017 |
Venue: Courtyard Marriott Montreal | 380 Rene-Levesque Boulevard West Meeting Room: Jackie Robinson |
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TORONTO |
Rescheduled to Tuesday, February 14, 2017 |
Venue: Sheraton Centre Toronto | 123 Queen St. W.Meeting Room: Birchwood Ballroom |
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CALGARY |
Wednesday, February 15, 2017 |
Venue: The Westin Calgary | 320-4 Ave SW Meeting Room: Eau Claire North/South |
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VANCOUVER |
Thursday, February 16, 2017 |
Venue: Pan Pacific Vancouver | 300-999 Canada Place Meeting Room: Coal Harbour |
Registration Info
(Fees include tax)
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1 Special: Registration + 2017 IFA membership |
2 YIN: Young IFA Network under 30 on January 1, 2017 |
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1,2 Special Offers valid for new members only / Offre spéciale valuable pour les nouveaux membres seulement |
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Cancellation: Full refund of registration fees for written cancellations received 3 weeks prior to the date of the lectureship. We regret that we cannot make refunds after that date. Substitutes are welcome. Annulation: Les personnes dont l’annulation écrite de l’inscription est reçue trois semaines avant la date de la conférence, se verront rembourser intégralement leurs frais d’inscription. Nous ne pouvons malheureusement accorder de remboursement après cette date. Nous acceptons les remplaçants. |
