255 Front Street West | North Building
Toronto, ON M5V 2W6
The 2025 IFA Canada Tax Conference will be taking place in-person in downtown Toronto at the Metro Toronto Convention Centre (health & safety permitting). There will not be a webcast / virtual option.
The focus of the program will be international tax issues that are impacted by international cross-border transactions.
Conference Co-Chairs:
John J. Lennard, Stikeman Elliott LLP, Toronto
Sharon Szeto, KPMG LLP, Toronto
On Monday, May 26th at 3:30 PM ET join us for an activity being led by members of the IFA Canada council:
Walk to The Well, Toronto’s newest landmark
Requires the ability to walk at a leisurely pace for up to 1.5-2 hours,.
The Well, a visionary project more than a decade in the making, has transformed 7.7 acres of Toronto’s King West area into a dynamic, European-influenced urban space. This expansive development is a mixture of modern living, working, and leisure.
Sign-up for this activity is separate from your registration, sign up using the button below!
8:00 AM – 9:00 AM
9:00 AM –
9:10 AM
9:10 AM –
10:15 AM
As many companies conclude their first Pillar 2 year (FY2024), uncertainties remain. Companies are required to monitor these ever-changing policies and proactively incorporate them into their M&A transactions. This session focuses on Pillar 2 and explores what this all means for M&A, including deal scoping, modeling, impacts to agreements and much more. An interactive panel of practitioners bring their diverse background to help you navigate the complex world of Pillar 2.
Moderator: Sue Wooles, BMO Financial Group, Toronto
Speakers:
Stephanie Dewey, McCarthy Tétrault LLP, Toronto
Leslie Ivany, EY LLP, Toronto
Megan Seto, Deloitte LLP, Toronto
Steve Tang, PwC LLP, Edmonton
YIN Rapporteur: Ugo Nobert, EY LLP, Montreal
Questions from the audience will be addressed at the end of the presentation.
10:15 AM –
10:35 AM
10:35 AM –
11:50 AM
The panel will discuss a number of cases released in the past 12 months that consider international tax issues or other questions of significance importance to international tax practitioners. The focus will be on Canadian jurisprudence but some non-Canada cases that are relevant to Canada will also be covered.
Moderator: Chris Sheridan, Blake, Cassels & Graydon LLP, New York
Speakers:
Jeremy Ho, McCarthy Tétrault LLP, Vancouver
Carolyn MacDonald, KPMG Law LLP, Vancouver
Aicha Nafii, Deloitte Legal Canada LLP, Montreal
Élisabeth Robichaud, Davies Ward Phillips & Vineberg LLP, Montreal
YIN Rapporteur: Connor Hasegawa, Davies Ward Phillips & Vineberg LLP, Toronto
Questions from the audience will be addressed at the end of the presentation.
11:50 AM –
1:20 PM
Keynote Session
1:20 PM –
2:20 PM
A cash pooling arrangement is an increasingly common method of centralized cash management employed by large multinational enterprises. On this panel, the speakers will (i) describe the two most common types of cash pooling arrangements, (ii) explore the various Canadian tax issues that arise in the context of both inbound and outbound cash pooling arrangements, and (iii) highlight some of the practical challenges that can arise under the Canadian tax rules.
Moderator: Sébastien Durand, EY LLP, Montreal
Speakers:
Nathalie Gagnon, EY Law LLP, Montreal
Kathleen Luan, Canada Revenue Agency, Toronto
Ehsan Wahidie, Deloitte LLP, Toronto
YIN Rapporteur: Brendan Festeryga, McCarthy Tétrault LLP, Toronto
A Young IFA Network (YIN) Presentation
Questions from the audience will be addressed at the end of the presentation.
2:20 PM –
3:20 PM
Dispositions of “taxable Canadian property” by non-residents of Canada are subject to the withholding and reporting obligations imposed by section 116 of the Income Tax Act. This presentation will cover the legal and practical challenges that can arise in connection with transactions involving non-residents, including purchase and sale transactions, corporate reorganizations, and estate planning. The presenters will also discuss practical examples and solutions that have been proposed.
Moderator: Ken Saddington, Goodmans LLP, Toronto
Speakers:
John Farquhar, Felesky Flynn LLP, Calgary
Olivia Khazam, Davies Ward Phillips & Vineberg LLP, Montreal
Jenna Schwartz, Richter LLP, Montreal
YIN Rapporteur: Jingcai Ying, Borden Ladner Gervais LLP, Toronto
Questions from the audience will be addressed at the end of the presentation.
3:20 PM –
3:40 PM
3:40 PM –
4:55 PM
This panel will discuss the various issues facing cross-border commerce, including i) an update/summary of where we are (even if changing frequently), ii) who bears the risks of tariffs and the importance of various contract and delivery terms, iii) Force Majeure and other contractual clauses to share or limit liability, or allow the contract to be terminated, iv) update on how the DST is or could be dealt with as part of the trade war, and v) transfer pricing issues caused by tariffs.
Moderator: Andrew Morreale, Baker & McKenzie LLP, Toronto
Speakers:
Jennifer Farrell, Western University, London
Alan Kenigsberg, Osler, Hoskin & Harcourt LLP, Toronto
Cortney Morgan, Husch Blackwell, Washington, DC
Wendy J. Wagner, Gowling WLG, Ottawa
YIN Rapporteur: Anela Luo, PwC LLP, Toronto
Questions from the audience will be addressed at the end of the presentation.
4:55 PM
5:30 PM
6:30 PM
7:30 AM –
8:30 AM
8:30 AM – 8:45 AM
8:45 AM – 9:00 AM
9:00 AM –
10:20 AM
The panel will discuss interesting cross-border M&A issues facing international tax practitioners today. The topics will include: (i) the use of earnouts and options to address tariff concerns, including exit tax considerations; (ii) M&A cross-border butterfly items to remember and the impact of accounting treatments on spin-off and reverse takeover transactions; (iii) the use of complex equity instruments in sale and joint venture transactions; and (iv) EIFEL due diligence and transaction consequences as well as cross-border M&A in the energy/renewables space.
Moderator: John Leopardi, Blake, Cassels & Graydon LLP, Montreal
Speakers:
Siwei Chen, Borden Ladner Gervais LLP, Calgary
Matthew McLellan, PwC LLP, Calgary
Benjamin Mann, Torys LLP, Toronto
Julie Bouthillier, KPMG Law LLP, Montreal
YIN Rapporteur: Graham Haynes, Stewart McKelvey, Saint John
Questions from the audience will be addressed at the end of the presentation.
10:20 AM –
11:30 AM
Moderator: Laura Gheorghiu, Gowling WLG, Montreal
Speakers:
Ian Caines, Davies Ward Phillips & Vineberg LLP, Toronto
Sam Ip, Osler, Hoskin & Harcourt LLP, Toronto
Kim Maguire, Osler, Hoskin & Harcourt LLP, Vancouver
YIN Rapporteur: Daiana Crisan, Deloitte LLP, Montreal
Questions from the audience will be addressed at the end of the presentation.
11:30 AM –
12:45 PM
12:45 PM –
1:45 PM
This panel will discuss cross-border financing matters with a focus on credit agreements, convertible debentures, and hybrid mismatch considerations.
Moderator: Jennifer Hanna, Borden Ladner Gervais LLP, Calgary
Speakers:
Laura Ball, BDO Canada LLP, Oakville
Evan Schmid, Blake, Cassels & Graydon LLP, Toronto
Manjit Singh, Aird & Berlis LLP, Toronto
YIN Rapporteur: Tong Kang Ju, CAE Inc., Montreal
Questions from the audience will be addressed at the end of the presentation.
1:45 PM –
2:05 PM
2:05 PM –
2:50 PM
Moderators:
Clara Pham, RSM Canada LLP, Toronto
Jill Winton, Stikeman Elliott LLP, Toronto
2:50 PM –
3:30 PM
Moderators:
Kristen Duerhammer, KPMG Law LLP, Toronto
Corinne Grigoriu, Cassels Brock & Blackwell LLP, Calgary
4:00 PM –
5:30 PM
The Women of IFA Network (WIN) is hosting a reception in connection with the IFA Canada Conference. WIN invites you to join for a drink, talk to some great women, and make lasting connections!
Please ensure you RSVP for this event as part of your registration checkout in order to attend.
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