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.



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


YIN Welcome




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

- C
anadian 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:



Conference Welcome & Opening Remarks




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., Vancouver

Anu Nijhawan, Bennett Jones LLP, Calgary

Jim Samuel, KPMG LLP, Calgary





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, Calgary

Shannon Baker, Cenovus Energy Inc., Calgary

Pierre Bourgeois, Raymond Chabot Grant Thornton LLP, Montreal

Steve Suarez, Borden Ladner Gervais LLP, Toronto




Keynote Address on the Role of Artificial Intelligence

With special guest speaker

Professor Benjamin Alarie, University of Toronto Faculty of Law

Sponsored by:






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.





Brian Mustard, Bell Canada, Montreal

Carrie Brandon Elliot, Contributing Editor, Tax Analysts, Tax Notes International

Siobhan Goguen, Felesky Flynn LLP, Calgary

Dr. Kenneth McKenzie, University of Calgary, Calgary

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

Session sponsored by:



Refreshment Break

Sponsored by:




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, Netherlands

Alan Connell, Eversheds Sutherland, Ireland

Ricardo Leon Santacruz, Sanchez DeVanny Eseverri, S.C., Mexico

Amanda Tickel, Deloitte LLP, London, UK






Cocktail Reception

Calgary Marriott Downtown Hotel
110 - 9 Avenue Southeast





Calgary Marriott Downtown Hotel
110 - 9 Avenue Southeast


Sponsored by:




YIN After Party

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

Sponsored by:



Agenda – Wednesday, May 16, 2018


Registration & Breakfast


IFA Canada Annual General Meeting



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



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., Calgary

Jonathan Greb, Baytex Energy Corp., Calgary

Annette Pilipiak, Nutrien, Saskatchewan

Steve Saunders, ATCO Ltd., Calgary



Refreshment Break



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, Calgary

Jennifer Hanna, MNP LLP, Calgary

Michael Kandev, Davies Ward Phillips & Vineberg LLP, Montreal

Angelo Nikolakakis, Ernst & Young Law LLP, Montreal



Buffet Lunch



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 York

Todd Schroeder, Norton Rose Fulbright, Dallas



Finance Roundtable




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

Brian Ernewein, Department of Finance, Ottawa



Refreshment Break



CRA Roundtable


More details to follow.





Delegate Pen Sponsor

WIFI Sponsor


Charging Station Sponsor

Registration Fees

GST (5%) will apply to all registration fees

On or Before April 16

Beginning April 17

IFA Member



Young Member1












Special Offer2



Special Offer - Young Member 1,2



Registration includes access to all Sessions, Electronic Materials, 2 breakfasts, 2 luncheons and Tuesday cocktail/dinner + YIN After Party.

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 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)




IFA 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 This email address is being protected from spambots. You need JavaScript enabled to view it.. 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.