New U.S.–Canada Cross Border Corporate Tax Challenges

Planning and Compliance Strategies After New Laws and Regulations

Recording of a 100-minute CPE/CLE webinar with Q&A


Conducted on Wednesday, March 18, 2009

Program Materials

This seminar will present an experienced panel of U.S. and Canadian tax advisors discussing their insights and strategies to deal with recent and emerging corporate tax developments for companies operating on both sides of the border.

Description

Canada is the U.S.' largest trading partner, so tax professionals at U.S. companies must actively monitor and understand changes in tax law and policy on both sides of the border.

For example, proposed U.S.-Canada tax treaty amendments address tax on cross-border income from certain services, plus mandatory dispute arbitration. U.S. tax pros must plan for Canada's conversion to IFRS accounting in 2011, and their Canadian counterparts must prepare for new IRS APA issues.

Corporate tax specialists for U.S. companies must stay current on how the latest guidance, tax laws and regulations in Canada affect the cost of doing business there through corporations and partnerships or through plants and branch offices. The same is true for Canadian companies operating here.

Listen as our panel of experienced tax advisors provides their analysis of and insights on the most recent, relevant developments in corporate tax on both sides of the U.S.-Canada border.

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Outline

  1. Latest Developments In U.S.-Canada Tax Treaty Protocol
    1. Proposed taxation of cross-border income from certain services
    2. Proposed use of mandatory dispute arbitration
    3. Recent guidance on definition of “carrying on business” in Canada
    4. New legislative withholding requirements effective in 2009
      1. Withholding tax on interest
    5. Impact of protocol on LLCs and ULCs
  2. Transfer Pricing Issues For U.S. Companies
    1. Recent U.S. service regulations
    2. Transfer issues with the protocol
    3. APA rollbacks (Canada-specific)
  3. Canada’s Conversion to IFRS Accounting In 2007-11 Period
    1. Impact on U.S. companies
    2. Critical tasks that must be met by 2011
  4. New IRS Advanced Pricing Agreement Issues
    1. Impact on Canadian companies doing business in U.S.
    2. Proposed changes in permanent establishment article

Benefits

The panel will discuss tax strategies on these new laws and emerging developments including:

  • The bottom line on the latest proposed treaty protocol amendments, and how they could change income tax bills and planning on both sides of the border.
  • Changes in how each country calculates "effectively connected" income from branches or partnerships.
  • The current status of U.S. and Canada taxation of royalties.
  • Strategies for planning for Canadian GST and consumption taxes.

Faculty

Rob Davis
Rob Davis
Partner
KPMG

He works in the firm's Transfer Pricing Practice and has 19 years in accounting firm tax, finance and transfer pricing...  |  Read More

John Lorito
John Lorito

Partner
Stikeman Elliott

He practices in the area of income tax, corporate reorganizations, mergers and acquisitions, and investment funds, with...  |  Read More

Howard Berish
Howard Berish

Partner
SNG Collins Barrow

He has practiced as a Chartered Accountant in Canada since 1979. He writes frequently on tax matters for the Montreal...  |  Read More

Lorne Richter
Lorne Richter

Partner
SNG Collins Barrow

He advises both U.S. and Canadian companies in cross-border tax planning and compliance. He frequently organizes tax...  |  Read More

Aly Lallani
Aly Lallani
Senior Manager in International Tax Practice
Deloitte & Touche

He works in the firm’s International Tax Practice focusing on cross-border tax issues affecting Canadian and U.S....  |  Read More

Dennis Alexander
Dennis Alexander
Partner
Deloitte & Touche

He is a partner in the Tax Reporting Services Practice where he focuses on assisting corporations with their Canadian...  |  Read More