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Back-to-Back Loan Rules

Presentation on the various Canadian “back-to-back” loans rules, including the rules applicable to Part XIII tax, shareholder loans, upstream loans and thin capitalization. The presenters will also provide practical examples of the application of these rules.

Moderator:

YIN Rapporteur:

Presenters:

Sara-Michelle Marcotte-Genier, PwC LLP, Montreal

Mathieu Champagne, Deloitte LLP, Montreal

Simon Lamarche, PwC Canada, Montreal

Designed for Young Members but all are welcome

The panelists will provide insights into  recent developments affecting cross-border financing. After a brief history of Canada- US financing structures, the panelists will discuss the impact of US tax reform on financing of US subsidiaries, including the proposed anti-hybrid regulations, some restructuring considerations and potential options going forward. The panel will also cover recent non-US developments affecting cross-border financing, in particular in the EU.

Sponsored by: 

Moderator:

YIN Rapporteur:

Presenters:

Reuben Abitbol, Davies Ward Phillips & Vineberg LLP, Montreal

Pierre Bourgeois, Raymond Chabot Grant Thornton LLP, Montréal

Jim Samuel, KPMG LLP, Calgary

Paul Seraganian, Osler, Hoskin & Harcourt LLP, New York

Louis Thomas, KPMG LLP, Luxembourg

Sponsored by:

11:30am

In recent years, several new mechanisms have been implemented to enhance tax transparency and exchanges of information between CRA and other tax authorities about assets and activities of multinational groups as well as individuals.  The CRA’s audit powers and their judicial interpretation have also evolved. 

This panel will discuss the status and direction of such tools and mechanisms, including:

•    Recent changes in CRA’s International and Large Business Directorate;
•    Third party data sources and the 3rd anniversary of the Panama papers;
•    New CRA and Revenu Québec strategic committee to exchange information relating to international tax activities;
•    Voluntary Disclosure Program for large corporation;
•    Treaty based requests;
•    ITA-based queries and formal requirements for information;
•    CRA’s new internal communique in information requests, including access to taxpayer’s tax provisions
•    Automatic international exchanges of tax rulings;
•    Country-by-Country reporting;
•    Electronic Funds Transfers;
•    FATCA and the Common Reporting Standards.

Moderator:

YIN Rapporteur:

Presenters:

Sue Murray, Canada Revenue Agency, Ottawa

Sébastien Rheault, Barsalou Lawson Rheault, Montreal

Keynote Address on the USMC Agreement

With special guest speaker
Raymond Bachand, Norton Rose Fulbright Canada, Montréal

This session will cover:

•    Recent legislative developments, including Budget 2019
•    Recent CRA technical Interpretations & rulings
•    Recent cases of interest 

Sponsored by:

Moderator:

YIN Rapporteur:

Presenters:

Romy-Alexandra Laliberte, Deloitte Tax Law, Montreal

Natalie Goulard, Department of Justice, Montreal

Nathalie Goyette, Davies Ward Phillips & Vineberg LLP, Montreal

Angelo Nikolakakis, EY LLP, Montreal

Christopher Steeves, Fasken, Toronto

Sponsored by:

The panelists will cover two broad topics:

(i) MLI implementation and;

(ii) taxation of the digital economy. The panel discussion will include an OECD and Department of Finance update, a review of developments at the EU level, in France and in select other European countries, and interaction between the panelists in respect of some of the practical issues raised by the PPT test in the MLI.

Sponsored by:

Moderator:

YIN Rapporteur:

Presenters:

Sophie Chatel, Head of the Tax Treaty Unit in the Centre for Tax Policy and Administration, OECD

Mark Dumalski, Deloitte LLP, Ottawa

Julien Gayral, Bredin Pratt, France, Paris

Stephanie Smith, Department of Finance, Ottawa

Sofitel Montréal Golden Mile Hotel

1155 Sherbrooke Ouest  |  Get Directions

Sofitel Montréal Golden Mile Hotel

1155 Sherbrooke Ouest  |  Get Directions

Sponsored by:

AIR Rooftop Terrace | Air Espace Terrasse

Join us for the YIN afterparty being held at the AIR Rooftop Terrace, a stylish restaurant, bar and lounge high above Montreal. Network on the outdoor terrace with the city as your backdrop.

1250 Boulevard Robert-Bourassa, Montréal | Get Directions

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BACK TO TOP

Subject 1:

National Reporter:

Subject 2:

National
Reporter:

In-house tax professionals will discuss the issues that are foremost for their enterprises such as current audit issues, matters related to international structuring and how they are responding to the changing international environment.

Sponsored by:

Moderator:

YIN Rapporteur:

Presenters:

Ilia Korkh, EY LLP, Vancouver

Patrick Bertrand, Pratt & Whitney Canada, Longueuil

Christine Couture, Alimentation Couche-Tard Inc., Laval

Pierre Lafontaine, Bombardier Inc., Montreal

Jean-François Ratté, PSP Investments, Montreal

Sponsored by:

The panelists will provide an overview of salient Canadian income tax considerations relevant to inbound (into Canada) acquisition and financing structuring. The first part of the presentation will outline a form of inbound structuring checklist with a focus on select topics. The second part of the presentation will provide some insight on select recent Canadian developments affecting inbound structuring.  The final portion of the presentation will provide a brief outline on select global developments that are rapidly evolving that impact cross-border structuring including in the M&A context.

Sponsored by:

Moderator:

YIN Rapporteur:

Presenters:

Rémi Gagnon, McCarthy Tétrault LLP, Montreal

John Leopardi, Blake, Cassels & Graydon LLP, Montreal

Eric Lévesque, Stikeman Elliott LLP, Montreal

Christian Meighen, McCarthy Tétrault LLP, Montreal

Digital taxes: it’s not just about technology companies?  The panelists will discuss the background and provide insights into global digital tax proposals , potential impacts and challenges. They will also look into how US tax reform from a transfer pricing perspective is fuelling the debate.

Moderator:

YIN Rapporteur:

Presenters:

Bhuvana Sankaranarayanan, Borden Ladner Gervais LLP, Ottawa

Hernan Allik, Deloitte LLP, Montreal

Emma Purdy, PwC Canada, Toronto

Scott Wilkie, Blake, Cassels & Graydon LLP, Toronto

Sponsored by:

US Tax Reform – Who Comes Out On Top?

•    Case studies on Canada-US cross-border investments to illustrate the principal effects of US tax reform.
•    The panel will focus on US tax considerations that arise in respect of US investments into Canada, and Canadian investments into the US.
•    Topics to include the BEAT, GILTI, 163(j), 367 and more.

Moderator:

YIN Rapporteur:

Presenters:

Robert Lee, Felesky Flynn LLP, Calgary

Gregg Benson, Davies Ward Phillips & Vineberg LLP, New York

William Cavanagh, Norton Rose Fulbright US LLP, New York

Moderators:

YIN Rapporteur:

Presenters:

Claire Kennedy, Bennett Jones LLP, Toronto

Emily Gilmour, Osler, Hoskin & Harcourt LLP, Toronto

Ted Cook, Director General, Tax Legislation Division, Department of Finance Canada, Ottawa

Stephanie Smith, Senior Director, Tax Treaties, Finance Canada, Ottawa

Presenters:

Carrie Smit, Goodmans LLP, Toronto

Yves Grondin, Canada Revenue Agency, Ottawa

Yves Moreno, Canada Revenue Agency, Ottawa

The event is full.

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 2019 IFA Membership plus Member rate for Seminar

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 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 ‘2019 IFA International Tax Conference’.

This program may be reported for up to 11 hours 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 Substantive Hours.

According to the Law Society of Ontario, 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.

This program has been approved and recognized by the Barreau du Québec for a total of 11 hours.

This program has been approved by the Law Society of Saskatchewan for up to 11 CPD hours.

IFA Canada has reserved a small block of rooms at the Sofitel Montreal Golden Mile 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 Friday, April 12, 2019. Delegates should make their own hotel arrangements by phone or email, referencing the IFA rate.

Toll Free 1-877-285-9001

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