Symposium June 2, 2008

 International Tax Reform:
Canada Confronts the Challenge

 A Symposium sponsored by
IFA (Canadian Branch), Canadian Tax Foundation, and Faculty of Law, University of Toronto

Monday, June 2, 2008
Metro Toronto Convention Centre
North Building, Room 201, Toronto ON

   IFA Logo                  CTF logo             University of Toronto Faculty of Law         

PRELIMINARY AGENDA

 8:00 am  Registration / Refreshments
 9:00 am  Opening Remarks
 Co-Chairs:  Ronald Durand, Stikeman Elliott LLP, Toronto
 W. Gordon Williamson, Deloitte & Touche LLP, Toronto
 9:00 am-10:10 am

 Economic Considerations in Setting Policy
 Jack Mintz, Palmer Chair in Public Policy, University of Calgary,
 Calgary

 • 
What are the objectives of international tax policy – neutrality 
    between domestic and foreign investments, competitiveness
    for Canadian multinationals?
 •  How important are taxes to FDI inbound and outbound
    investment?
 •  How do these objectives play out when thinking about the big
    issues – treatment of foreign income (active versus passive),
    deductability of overhead costs for foreign investments,
    withholoding taxes?
 •  How good is the Canadian system today in achieving a balance
    amongst these objectives?

 10:10 am -10:30 am  Morning Break
 10:10 am-10:30 am

How other countries tax foreign income (a survey of
other countries – how their exemption systems work;
how passive income vs. active income is dealt with, other
base erosion protection; deeming rules to deal with inter-company
payments for interest, royalties, etc.)
Trent Henry, Ernst & Young LLP, Toronto
 • 
A review of how other countries are dealing with these issues;
    trends and other considerations

 11:15 am-12:00 pm Taxation of Foreign Income (consideration of how Canadian tax
rules should be modified to achieve the correct the correct
balance of supporting international investment and protecting
the Canadian corporate tax base)
David G. Duff, Professor, Faculty of Law, University of
Toronto, Toronto ON
Trent Henry, Ernst & Young LLP, Toronto ON
Stephen S. Ruby, Davies Ward Phillips & Vineberg LLP,
Toronto ON
• 
Suggest a Canadian approach, taking into account the
    experiences of and evolving practices in other countries, the
    position of Canada in the North American and world economy,
    and the other aspects of the Canadian system for taxing
    international income. Discussion should also focus on some of
    the practical aspects of implementing any suggested changes.
 12:00 pm -1:15 pm Lunch Break 
 1:15 pm – 2:00 pm

Thin Capitalization and Expense (Interest) Allocation Rules
(a survey of other country practices)
Sandra Slaats, Deloitte & Touche LLP, Toronto ON
•  A review of how other countries are dealing with these issues; 
   trends and other considerations

 2:00 pm – 2:45 pm Thin Capitalization and Expense (Interest) Allocation Rules
(considerations on how should Canadian rules be modified to
achieve the correct balance of supporting international investment
and protecting the Canadian corporate tax base)
Tim Edgar, Professor & Associate Dean, Faculty of Law,
University of Western Ontario, London ON
Shawn D. Porter, Deloitte & Touche LLP, Toronto ON
Sandra Slaats, Deloitte & Touche LLP, Toronto ON
• 
Suggest a Canadian approach, taking into account the experiences
   of and evolving practices in other countries, the position of Canada
   in the North American and world economy, and the other aspects
   of the Canadian system for taxing international income. Discussion
   should also focus on some of the practical aspects of implementing
   any suggested changes.
 2:45 pm – 3:10 pm Afternoon Break 
 3:10 pm – 4:30 pm “Where Do We Go From Here?”
Robert Couzin, Couzin Taylor/Ernst & Young LLP, Toronto ON
Jack M. Mintz, Palmer Chair in Public Policy, University of Calgary
H. David Rosenbloom, Caplin & Drysdale Chartered, Washington DC USA
J. Scott Wilkie, Osler Hoskin & Harcourt LLP, Toronto ON
• 
A roundtable discussion of the issues raised in the prior sessions
   together with reflection on the rewards for Canada in choosing
   an appropriate path through International Tax Reform and the
   perils of not doing so.
 4:30 pm Symposium Adjournment 
 4:30 pm Cocktail Reception 

ONLINE REGISTRATION
Go to the Foundation website www.ctf.ca and follow the link on the What’s New page

   Before May 20 After May 20 
 Practitioner $275  $325 
 Student/Academic/Government  $95 $145

Registration includes access to sessions, Symposium materials, continental breakfast,
and luncheon.
Cancellation: Full refund for written cancellations received by the Conference Department
at the Foundation’s Toronto office until 5:00 pm EDT prior to May 20, 2008.
Substitutes are welcome.

 

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