U.S.-Canada Cross Border Corporate Tax Challenges
Planning and Compliance Strategies Given Latest Guidance and Regulation Changes
Recording of a 110-minute CLE webinar/teleconference with Q&A
Conducted on Wednesday, October 6, 2010
Recorded event now available
This CLE webinar will provide tax professionals with a review, by an experienced panel of Canadian tax advisors, of recent and emerging corporate tax developments for U.S. companies. The panel will outline areas where compliance and planning must be adjusted.
Description
As U.S. companies continue phasing in important compliance and tax planning changes required by the U.S.-Canada Income Tax Convention (Treaty)'s Fifth Protocol, recent developments involving Canadian tax policy toward American businesses also command their attention.
High-visibility actions include new Canada Revenue Agency policy statements on business entities and evolving written positions on hybrid structures, interpretive guidance on limitation on benefits regulations, and liberalized regulations on taxing income from U.S.-held shares in Canadian companies.
There are also important Canadian court rulings on transfer pricing, pending revisions on regulations for controlled foreign corporations and foreign trusts, and transfer pricing guidelines for multinationals. Tax professionals for U.S. firms doing business in Canada need to stay up to date.
Listen as our panel of experienced tax advisors offers analysis of and insights into the most recent, relevant developments in corporate tax in Canada that affect U.S. companies.
Outline
- Recent developments in Canadian tax policy and regs
- CRA policy statements on entities and entity formation
- Written position and changes in stance toward hybrid entities
- Important remaining questions for taxpayers about post-protocol years
- Interpretive guidance on limitation on benefits regs
- Reg changes on U.S. taxpayer sales of shares in Canadian companies
- Proposed reg revisions for CFCs and foreign trusts
- Transfer pricing issues for U.S. companies
- Recent court rulings
- Pending changes in transfer pricing guidelines for multi-nationals
- Review of important aspects of Fifth Protocol to tax treaty
- Canada’s conversion to IFRS accounting in 2007-11 period
- Impact on U.S. companies
- Critical tasks that must be met by 2011
Benefits
The panel will address tax implications arising from these and other emerging developments in Canada:
- Interpretive guidance involving entity formation, use of hybrid business structures, and limitations on benefits.
- Updates or changes to regulations affecting stock sales, foreign trusts and foreign affiliates.
- Key court decisions and proposed new guidelines with a material impact on transfer pricing policy.
- Continuing adjustments to the terms of the tax treaty Fifth Protocol.
Upon completion of this webinar, you will be thoroughly briefed on material recent developments with policy guidance, regulatory changes and court rulings in Canada that affect U.S. companies and business entities with income tax obligations north of the border.
Faculty
Jonathan Garbutt,
Barrister and Solicitor
Garbutt Tax Law, Toronto, ON, Canada
His practice covers general tax planning and tax minimization, M&A tax matters, international private investment and tax controversy and litigation, transfer pricing, and Canadian trusts and estates law. He previously worked with Baker & McKenzie in Toronto.
Merv Edwards,
Managing Director
Ceteris Canada Inc., Toronto, ON, Canada
He manages a wide range of transfer pricing engagements for clients in industries ranging from technology to pharmaceutical to consumer goods. He has more than 16 years of transfer pricing experience, including five years with the Canada Revenue Agency.
Duane Milot,
Cassels Brock, Toronto, ON, Canada
He is assigned to the firm's tax and trusts group, where his practice focuses on general corporate income tax law for domestic and international matters. His experience also includes international tax planning, cross-border tax and transfer pricing. He represents taxpayers before the Canada Revenue Agency and provincial authorities.
Ordering
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Customer Reviews
Timely coverage of a complicated subject.
William Ahlstrom
Kerber Eck & Braeckel
This teleconference greatly helped us understand the new challenges.
Andrew Toth
Tronconi Segarra & Associates
Very interesting, informed us on the most recent updates.
Kristin Thompson
Global Tax Management
The program had excellent presenters that were extremely knowledgeable.
Lisa R. Volland
Legacy Professionals
Coverage was practical and straightforward. Well done.
Stuart J. Frentz
Bradley Arant Boult Cummings
Federal Income Tax Advisory Board
David Bowen
Principal
Grant Thornton
Joseph Calianno
Partner, National Tax Practice
Grant Thornton
Of Counsel
Morrison & Foerster
George Manousos
Partner
PricewaterhouseCoopers
Federal Tax Partner
Nixon Peabody
Tax Controversy Partner
Crowell & Moring
Of Counsel
Skadden Arps
Tom Windram
Managing Director & National Leader, Federal Tax Credits & Incentives
RSM McGladrey
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