Taking place in-person in Toronto.
Streaming live simultaneously from offices in Vancouver, Calgary, Ottawa and Montreal.
Lectureship Overview
Beneficial ownership is a fundamental concept in determining a taxpayer’s entitlement to tax treaty benefits. Longstanding jurisprudence in Canada has recently been reconsidered by the Federal Court of Appeal in Canada. Speakers Błażej Kuźniacki and Robert Raizenne will discuss the elaboration and historical development of the beneficial ownership concept and the role the concept currently plays in international taxation. The scope of beneficial ownership as defined in sometimes conflicting international jurisprudence and the parameters set by the OECD will be discussed. The speakers will also comment on its future role in a changing international taxation landscape, addressing continuing uncertainty in this area.
This lectureship will be delivered live and in person in Toronto on Tuesday, February 24.
In addition, satellite viewing events will take place in Vancouver, Calgary, Ottawa, and Montreal, where attendees will watch the live lecture together in a meeting space and be able to participate in the live Q&A.
There is no individual or at-home webcast option.
TORONTO
11:00 AM – 2:45 PM EST
Offices of Gowling WLG
100 King St W
Suite 1600
Toronto, ON M5X 1G5
VANCOUVER
8:00 AM – 11:45 PM PST
Offices of Gowling WLG
550 Burrard Street
Suite 2300
Vancouver, BC V6C 0B3
CALGARY
9:00 AM – 12:45 PM MST
Offices of Gowling WLG
421 7 Ave SW
Suite 1600
Calgary, AB T2P 4K9
OTTAWA
11:00 AM – 2:45 PM EST
Offices of Gowling WLG
160 Elgin Street
Suite 2600
Ottawa, ON K1P 1C3
MONTREAL
11:00 AM – 2:45 PM EST
Offices of Gowling WLG
1 Pl. Ville-Marie
Suite 3700
Montreal, QC H3B 3P4
Program Agenda (PST / MST / EST)
8:00 am PST | 9:00 am MST | 11:00 am EST
Registration / Check-in
8:15 am PST | 9:15 am MST | 11:15 am EST
Lectureship
11:45 am PST | 12:45 pm MST | 2:45 pm EST
Adjournment
Błażej Kuźniacki, Global Tax Policy & International Tax Services at PwC Netherlands | Professor of Law at Lazarski University | Senior Research Affiliate at Singapore Management University
Błażej Kuźniacki is a tax practitioner with qualification as an attorney-at-law (Warsaw Bar Association), currently working at PwC Netherlands (Amsterdam office) with International Tax Services Team and the PwC Global Tax Policy Team. Błażej provides a strategic tax advice on international tax law and global tax policy. He also is the award-winning author of more than 150 scientific publications with national and global coverage, including four books. For the book “Beneficial Ownership in International Taxation” (2022), Błażej was awarded with the International Fiscal Association (IFA) Mitchell B. Carroll Prize in 2023.
Many authoritative sources, e.g. apex courts in Brazil, Poland and Switzerland, the OECD, the WBG, and the CIAT cite Błażej’s work to support their reasoning in jurisprudential and tax policy pieces. He speaks frequently on international tax law, investment tax related disputes and tax XAI (eXplainable AI) next to his practice in these fields, including expert witness’s opinions.
Robert Raizenne, Tax Partner, Osler, Hoskin & Harcourt LLP, Adjunct Professor of Tax Law at McGill University’s Faculty of Law, and the Faculty of Law at the University of Toronto
Robert Raizenne has extensive experience in a wide variety of transactions and tax planning matters, including cross-border and domestic mergers and acquisitions, corporate reorganizations and restructurings, corporate finance, international tax and trusts. He is also an experienced tax litigator.
Robert is an adjunct professor of tax law at McGill University’s Faculty of Law and the Faculty of Law at the University of Toronto, and a sought-after speaker and writer on tax topics. He has spoken frequently at the Canadian Tax Foundation’s Annual Conference, the Annual Conference of the Canadian Branch of the International Fiscal Association and many other professional venues.
Regular Member – $165
Young Member – $55
Academic Member – $55
Student – $10
Provincial Sales Tax will apply to registration fees at checkout.
Government (IFA Member or Non-Member) – $90
This rate is for employees of recognized government institutions. Validation may be required.
Provincial Sales Tax will apply to registration fees at checkout.
Non-Member – $220
Young* – $75
Academic** – $75
Student*** – $10
Special Offer – Membership + Registration – $275
Special Offer – Young Membership + Registration – $120
Special Offer – Academic Membership + Registration – $120
IMPORTANT NOTES
Provincial Sales Tax will apply to registration fees at checkout.
Special Offer Details: IFA Membership for the 2026 year and in-person registration to the conference at a discounted rate. Applies to new members only.
Special Offer Young membership: Must be under 30 years of age as of January 1st, 2026. Applies to new members only.
Other Notes:
* Young Non-Member: DOB must be provided at check-out. Those under 30 years of age as of January 1, 2026, qualify.
** Full-time academics are professors with a valid email address from a recognized institution only.
*** Students must be full-time and need an email address from a recognized educational institution. Articling students and those already working in their profession do not qualify. Further proof may be required.
This program contains 3 substantive hours.
ALBERTA
For Alberta lawyers, consider including this program as a continuing professional development (CPD) learning activity in your annual CPD plan.
The Law Society of Alberta (LSA) requires all active lawyers to submit an annual CPD plan by October 1 each year, using the online CPD Tool (accessible through the Lawyer Portal). Each plan must (1) identify at least two competencies from the LSA’s Professional Development Profile, (2) include self-assessed proficiency ratings, and (3) outline corresponding learning activities. The LSA’s CPD program emphasizes self-directed learning and does not impose a minimum hour requirement or maintain an accreditation process for third-party courses or continuing legal education (CLE) providers. Instead, lawyers are encouraged to choose learning activities that align with their individual professional needs and development goals. For full details, see the CPD page on the LSA website.
BRITISH COLUMBIA
For British Columbia lawyers, this program is eligible for up to 3 CPD credits.
The Law Society of British Columbia (LSBC) requires all practising lawyers to complete 12 hours of accredited CPD activity each calendar year, including at least two hours focused on professional responsibility and ethics, practice management, or client care and relations. Eligible CPD activities include accredited courses, interactive online programs, teaching, writing, mentoring, and providing pro bono legal services. Lawyers are responsible for recording their CPD activities through the LSBC’s online self-reporting system. Click here to log in to the LSBC’s website and report your credits.
MANITOBA
For Manitoba lawyers, this program counts for up to 3 hours of eligible CPD activity.
The Law Society of Manitoba (LSM) requires all practising lawyers to complete 3 hours of eligible CPD activity annually by December 31. Eligible CPD activities include live programs, workshops, interactive online courses, group discussions, teaching, and certain writing projects. Lawyers are responsible for tracking and reporting their CPD activities through the CPD tracker (accessible via the LSM member portal) by April 1 the following year. Unlike some jurisdictions, the LSM does not formally accredit specific providers or programs; instead, it sets content-based eligibility criteria and leaves it to members to ensure that their chosen activities meet the CPD requirements. For details, see the Mandatory CPD page on the LSM website.
NEW BRUNSWICK
For New Brunswick lawyers, this program counts for up to 3 hours of eligible CPD activity.
The Law Society of New Brunswick (LSNB) requires all practising lawyers to complete a minimum of 3 hours of CPD annually, including at least 2 hours focused on professional responsibility and ethics. These hours must be completed and self-reported through the LSNB member portal by December 31 each year. Qualifying activities include courses, conferences, structured group learning, teaching, and published legal writing. As of January 1, 2023, the LSNB no longer accredits individual providers or programs; instead, lawyers are responsible for ensuring that their CPD activities align with the LSNB’s eligibility criteria. For details, see the CPD page on the LSNB website.
NOVA SCOTIA
For Nova Scotia lawyers, consider including this course as a CPD learning activity in your annual CPD plan as required by the Nova Scotia Barristers’ Society (NSBS).
The NSBS requires all practising lawyers to complete a written CPD plan by June 1 each year. While there is no mandatory hour requirement, lawyers are expected to complete approximately 12 hours of CPD activity annually, aligned with the goals set out in their plan. The NSBS does not accredit or pre-approve courses offered by CLE providers. Instead, members are responsible for selecting learning activities that support their professional competence and reflect the competencies outlined in the Society’s CPD framework. For details on the NSBS’s CPD requirements, see the CPD page on the NSBS website.
ONTARIO
For Ontario lawyers, this program is eligible for up to 3 substantive hours of CPD.
“Substantive hours” refer to educational activities that increase a lawyer’s or paralegal’s professional knowledge and skills related to substantive or procedural law, legal theory, and the practice of law. These hours can include learning in areas such as litigation, legal research, negotiation, drafting, and other legal competencies. Substantive content does not require accreditation by the Law Society of Ontario (LSO), providing flexibility in how Ontario lawyers and paralegals fulfill this component of the CPD requirements. Ontario lawyers and paralegals must complete all required CPD hours by December 31 each year and report them through the LSO Connect portal by March 31 of the following year. For details, see the LSO’s CPD Requirement page.
SASKATCHEWAN
For Saskatchewan lawyers, this program qualifies for 3 CPD hours under the Law Society of Saskatchewan (LSS) CPD Policy.
The LSS requires all active members to complete and report a minimum of 12 hours of CPD annually, including at least 2 hours focused on ethics-related topics, such as professional responsibility, practice standards, and client care. As of January 1, 2024, the LSS discontinued its accreditation process, allowing members to select their own qualifying activities without prior approval, provided that those activities meet the subject matter criteria in section 6 of the CPD Policy. Lawyers are responsible for self-reporting their CPD hours through their Member Profile on the LSS website.
QUEBEC
For Québec lawyers, this program may qualify for 3 CPD hours under the Barreau du Québec’s Mandatory Continuing Legal Education (MCLE) framework. CPD activities completed outside the Province of Québec are automatically recognized by Quebec’s Comité sur la formation continue obligatoire, provided they are approved by another Canadian or foreign bar association as part of its own CPD or MCLE program. It is the responsibility of the Québec lawyer to verify that the activity qualifies as CPD under the foreign bar’s program and that it meets the requirements of the Règlement sur la formation continue obligatoire (that is, the regulation, enacted by the Barreau du Québec, that governs CPD for lawyers practising in the province).
The Barreau du Québec requires all active members to complete at least 30 hours of CPD over a two-year period, including a minimum of 3 hours related to ethics, professional conduct, or professional practice, from activities recognized by the Barreau. (The current reference period began on April 1, 2025 and ends on March 31, 2027.) Members must report completed activities, with supporting proof of registration and participation, in their online training record—accessible via the member portal—by March 31 of the final year of the reference period. No separate application for recognition is required.
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