May 5, 2021
This was our first (and hopefully last) full pandemic year – filled with lock downs, zoom calls and remote working. Nevertheless, this has continued to be a very busy year in the world of IFA and international tax. The remainder of 2021 year promises to continue to be busy – with the relatively recent coming into force of the MLI, various international tax changes in Budget 2021, pending international tax cases at the Supreme Court of Canada (Alta Energy and Loblaw), the considerable volume of work being done by the OECD/G20/Inclusive Framework – including the Pillar One and Pillar Two proposals, and various other international tax matters.
We had a successful (virtual) “Travelling Lectureship” earlier this year, with Prof. Miranda Stewart presenting on “Corporate Residence, Legal Fictions and Tax Jurisdiction”. In particular, we took advantage of the current virtual environment to get the benefit of a speaker from Australia – who was also (somewhat surprisingly) our first female sole-lecturer (together with a useful intervention from Prof. Jinyan Lee).
2021 has also seen continued successes in YIN engagement, with the continuation of YIN Study Group meetings and webinars. I want to thank Kim Brown and the rest of the YIN Committee for continuing their significant engagement, and building the foundation for the future of IFA in Canada. Recognizing the importance of YIN to future of our membership, we have invited Kim Brown (as the Chair of the YIN Committee) to attend all of our Executive Committee meetings – and we plan to continue this approach going forward to ensure continued close collaboration with our various YIN initiatives. In addition, we have recently launched a new YIN outreach – which includes free membership for a year to qualifying individuals.
Earlier this week we had a successful inaugural (virtual) North American Region meeting – which was closely followed by our Canadian Branch annual conference yesterday and today. The NA Region was officially launched in the Fall of 2020, and the Canadian Branch took the lead in chairing the region for 2021. (The Mexican Branch will take the chair in 2022, followed by the US Branch in 2023).
We also hosted a successful (scaled-down) virtual event in the Fall of 2020 – which set us up well for hosting the various events referred to above in 2021. I want to thank Amanda Heale and Phil Halvorson for all of their hard work organizing the 2021 events – together with support from Lynn Moen, Michael Kandev and others – and look forward to a successful Canadian Branch conference in 2022 (which will hopefully include an “in person” component). I also want to thank Michael Davis – for all of his hard work in finding sponsors for our various events.
Looking further ahead, the Canadian Branch submitted a bid in 2020 to host a future IFA Congress in either Toronto or Montreal. While Central IFA indicated that our bid would have been successful – they have temporarily suspended allotting future congresses (with the current plan to host a virtual congress from Nov 29 to Dec 1, 2021, followed by congresses in Berlin 2022, Cancun 2023, etc – which each of the allotted congresses being pushed back by two years). Special thanks to Ken Buttenham, Chris Steeves, and Steve Suarez for all of their hard work in getting the Canadian Branch bid materials to the finish line (together with the critical support from the CTF and Helen Mullins at Conference Direct). We remain hopeful that we will eventually host another IFA Congress – and that the pandemic will be a distant memory by the time we do!
IFA Canada very much appreciates the past work at Central IFA by Scott Wilkie and Brian Schneidermann, and we are optimistic that Canada will continue to be represented at IFA Central once their current reorganization is complete.
I want to thank those at the Canadian Tax Foundation for their hard work and assistance in supporting IFA regarding its administrative functions and for special attention given to helping us organize our many virtual events this year – as well as keeping us organized and functional throughout the year. Thank you in particular to Robyn Corrigan, Rachelle Terte, and Shelly Ali – together with the rest of the CTF team.
I also want to thank Anu Nijhawan, Kim Maguire and others for advancing the WIN initiative (both within the Canadian branch and more broadly within IFA). In particular, the WIN group organized a successful chocolate tasting event – managing to promote networking and engagement despite the current pandemic restrictions.
I would also like to thank our National Reporters for the Cancun and Berlin Congresses (despite the fact that those congresses have not yet been held):
- Subject 1: (2020) Reconstructing the Treaty Network – Kim Brooks, Jim Samuel and Shaira Nanji
- Subject 2: (2020) Exchange of Information issues, use and collaboration (CbC, Master file) and the attorney-client privilege principle – Sebastian Rheault and Carolle Fernando
- Subject 1: (2021) Group Approach and Separate Entity Approach in Domestic and International Tax Law – Sarah Chiu and Sunita Doobay
- Subject 2: (2021) Big Data and Tax – Domestic and International Taxation of Data Driven Business – Marie-Emmanuelle Valliancourt and Mathieu Champagne
Finally, I would like to take the opportunity to thank the members of IFA Canada’s Executive Committee: Michael Kandev, Claire Kennedy, Kim Maguire, Lynn Moen, and Brian Mustard for all of their hard work and commitment to IFA Canada.
I hope that everyone has an enjoyable remainder of 2021, and that we can all continue to stay engaged and connected within the IFA Community!
Patrick Marley
Osler, Hoskin & Harcourt LLP
Toronto
