2018 Conference

IFA Canada’s International Tax Conference is coming back to Calgary!

The Conference will be held in Calgary at the Telus Convention Centre in the centre of downtown at 120 – 9 Ave SE. The focus of the program will be international tax issues that are impacted by international cross-border transactions. 

» Attendees: The conference materials are now available! 


Deirdre Choate, Husky Energy Inc., Calgary
Siobhan Goguen, Felesky Flynn LLP, Calgary

Agenda – Tuesday, May 15, 2018  


Breakfast | Registration Desk Opens

Sponsored by: 

Pre-Conference Session 
8:25amYIN Welcome 
8:30am YIN In-Depth: International Tax Issues for Partnerships
This presentation will review issues applicable to partnerships in the international context. 

Topics covered will include:

– the nature and classification of partnerships in a cross-border context

– Canadian tax implications where a partnership is investing inbound into Canada including thin capitalization rules, withholding taxes, applicability of tax treaties, the foreign affiliate dumping rules and taxable Canadian property implications

– selected Canadian tax issues to consider where a partnership with Canadian partners will be investing in a non-Canadian corporation

YIN Rapporteur:

 Ilia Korkh, EY Law LLP, Vancouver

Brian Milne
, Norton Rose Fulbright Canada LLP, Calgary

Michael Dolson, Felesky Flynn LLP, Edmonton Dan Jankovic, Blake, Cassels & Graydon LLP, Calgary Janette Pantry, Ernst & Young LLP, Vancouver 
Designed for Young Members but all are welcome


Conference Registration | Refreshment Break 

Sponsored by:

9:55amConference Welcome & Opening Remarks 
10:05am Cross-Border Cash Pooling Arrangements – Some Practical Problems

This panel will focus on the practical issues of cross-border cash pooling arrangements in Canada including:

– What cash pooling means from a tax technical and treasury standpoint;

– How companies are currently navigating the existing Canadian tax rules and the challenges they face when conducting cross-border cash pooling in Canada; and

– Potential legislative and/or practical solutions that may allow Canadian corporations to cross-border cash pool.

YIN Rapporteur:

 Peter van Dijk, PwC Canada, Toronto 

Yufei Ho, PwC Canada, Toronto

Ari Morris, Global Treasury Partners Ltd., VancouverAnu Nijhawan, Bennett Jones LLP, CalgaryJim Samuel, KPMG LLP, Calgary
11:05am  Recent Canadian Developments

OECD Digital Economy Report

Foreign Affiliate Update
– Budget Announcements
– Recent Technical Interpretations of Interest

Current Compliance Issues
– Budget Announcements
– Voluntary Disclosure Program
– Managing Information Returns

YIN Rapporteur:

 Claire Kennedy, Bennett Jones LLP, Toronto

Jared Mackey, Bennett Jones LLP,  Calgary

Brett Anderson
, Felesky Flynn LLP, CalgaryShannon Baker, Cenovus Energy Inc., CalgaryPierre Bourgeois, Raymond Chabot Grant Thornton LLP, MontrealSteve Suarez, Borden Ladner Gervais LLP, Toronto
Keynote Address on the Role of Artificial Intelligence

With special guest speaker Professor Benjamin AlarieUniversity of Toronto Faculty of Law

Sponsored by:
1:45pm  US Tax Reform

This panel will discuss recent trends and developments in Canadian cross-border M&A. The panelists will present an overview of recent Canadian cross-border M&A transactions and will discuss practical structuring issues arising in connection with cross-border transactions, as well as current trends and considerations relating to investments in, and exit from, Canada.

YIN Rapporteur:

 Brian Mustard, Bell Canada, Montreal

Marie-Soleil Landry, McCarthy Tétrault LLP, Montreal

Carrie Brandon Elliot, Contributing Editor, Tax Analysts, Tax Notes International Siobhan Goguen, Felesky Flynn LLP, CalgaryDr. Kenneth McKenzie, University of Calgary, CalgaryPaul Seraganian, Osler, Hoskin & Harcourt LLP, New York

Session sponsored by:


Refreshment Break

Sponsored by:

3:35pm International Tax Agenda Roundtable, including BEPS & Brexit: the Canadian Tax Impact

This panel will discuss recent developments in the European Union and Mexico including the EU response to the digital economy, mandatory disclosure, Brexit and new gateways to the European Union, country responses to the Multilateral Instrument and the impact of trade agreements on taxation and limitation of benefit provisions.

YIN Rapporteur:

 Prof. Catherine Brown, Faculty of Law, University of Calgary

Monica Cheng, Blake, Cassels & Graydon LLP, Calgary

Marja de Best, Loyens & Loeff, NetherlandsAlan Connell, Eversheds Sutherland, IrelandRicardo Leon Santacruz, Sanchez DeVanny Eseverri, S.C., MexicoAmanda Tickel, Deloitte LLP, London, UK
6:00pmCocktail ReceptionCalgary Marriott Downtown Hotel 
110 – 9 Avenue Southeast
7:00pmDinnerCalgary Marriott Downtown Hotel 
110 – 9 Avenue Southeast
 Sponsored by:

9:00pmYIN After Party 

National Bowl
Lower level of National on 10th
341 – 10th Avenue SW | Directions

Sponsored by:

Agenda – Wednesday, May 16, 2018 
7:30amRegistration & Breakfast
8:15amIFA Canada Annual General Meeting
8:30am IFA 2018 Congress Reports
Subject 1: Anti-Avoidance Measures of General Nature and Scope, GAAR, and Other Rules
 Anu Nijhawan, Bennett Jones LLP, Calgary
Subject 2: Withholding Tax in the Era of BEPS, CIVs, and Digital Economy
 Natasha Miklaucic, Borden Ladner Gervais LLP, Toronto
8:50am Tax Directors’ Roundtable: Pressing Topics from the Front Lines

The Tax Directors’ Roundtable will discuss the challenges of international tax planning in the current global environment, managing the compliance burden and tax provision when rules keep changing, and the impact of rapidly changing technology on the tax function. 

YIN Rapporteur:

 Deirdre Choate, Husky Energy Inc., Calgary

Polly Savage, Husky Energy Inc.,Calgary

Matt Billings, Duff & Phelps, Toronto Deirdre Choate, Husky Energy Inc., CalgaryJonathan Greb, Baytex Energy Corp., CalgaryAnnette Pilipiak, Nutrien, Saskatchewan
Steve Saunders, ATCO Ltd., Calgary
10:10am Refreshment Break
10:30am Recent Transactions of Interest

This panel will discuss recent trends and developments in Canadian cross-border M&A.  The panelists will present an overview of recent Canadian cross-border M&A transactions and will discuss practical structuring issues arising in connection with cross-border transactions, as well as current trends and considerations relating to investments in, and exit from, Canada.

YIN Rapporteur:

 Patrick Marley, Osler, Hoskin & Harcourt LLP, Toronto

Corinne Grigoriu, Osler, Hoskin & Harcourt LLP, Calgary

Nancy Diep, Blake, Cassels & Graydon LLP, CalgaryJennifer Hanna, MNP LLP, CalgaryMichael Kandev, Davies Ward Phillips & Vineberg LLP, MontrealAngelo Nikolakakis, Ernst & Young Law LLP, Montreal
11:45am Buffet Lunch
1:00pm Select U.S. Legislative & Case Law Developments

This session will cover the following topics:
– Change in the CFC rules (attribution and definition of “U.S. shareholder”)

– Choice of entity for inbound investment 
– Impact of tax reform on M&A structures and repatriation of profits 
– Self initiated adjustments and Voluntary disclosures for transfer pricing. The potential double tax under Mutual agreement procedure between CRA and IRS

YIN Rapporteur:

 Dale Hill, Gowling WLG (Canada) LLP, Ottawa

Laura Gheorghiu, Gowling WLG (Canada) LLP, Montreal

Jim Barry, Mayer Brown, Chicago
Kevin Colan, Osler, Hoskin & Harcourt LLP, New YorkTodd Schroeder, Norton Rose Fulbright, Dallas 
2:00pm Finance Roundtable

YIN Rapporteur:

 David Weekes, Stikeman Elliott LLP, Calgary
Stephen Bowman, Bennett Jones LLP, Toronto

Wade Ritchie, Bennett Jones LLP, Calgary

Dave Beaulne, Department of Finance, Ottawa
Brian Ernewein
, Department of Finance, Ottawa
2:50pm Refreshment Break
3:05pm CRA Roundtable

 Lynn Moen
Doug Powrie, Vice President Tax, Teck Resources Ltd.

Milled Azzi, CPA, CA, Director, International Division, Income Tax Rulings Directorate, Legislative Policy and Regulatory Affairs Branch

Lori Carruthers, CPA, CA, Manager, International Division, Income Tax Rulings Directorate, Legislative Policy and Regulatory Affairs Branch
4:00pm Adjournment
Delegate Pen Sponsor

WIFI Sponsor

 Charging Station Sponsor

Registration Fees

GST (5%) will apply to all registration fees
On or Before April 16Beginning April 17
IFA Member$645$745
Young Member1$595$695
Special Offer2$745$845
Special Offer – Young Member 1,2$615$715
Registration includes access to all Sessions, Electronic Materials, 2 breakfasts, 2 luncheons and Tuesday cocktail/dinner + YIN After Party. 

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

Special Offer: New IFA Canada Members Only: Discounted 2018 IFA Membership plus Member rate for Seminar
IMPORTANT: Your registration includes 1 Ticket for the Tuesday, May 15, 2018 dinner and access to the Tuesday 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)

AccommodationsIFA Canada has reserved a block of rooms at the Calgary Marriott Downtown 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 16, 2018. Delegates should make their own hotel arrangements by booking online via the below reservation link.

The roomblock has ended.Click here to visit the Calgary Marriott website for Room bookings. 
Toll Free 1-800-228-9290
Calgary Marriott Downtown Hotel
110 – 9th Avenue SE 
Calgary, AB T2G 5A6

 Get Directions
single/double – $199
Available May14 – May 17, 2018

Accreditation Information 

» You can request an Attendance Letter here. Attendance letters will only be distributed after the conference.

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 ‘2018 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.

This program is eligible by the Law Society of Saskatchewan for up to 11.5 CPD hours. 

Lawyers are required to self-report their CPD activities in their Member Profile through the Law Society’s website.