U.S.-Canada Corporate Tax Challenges With Surge in Cross Border Deals, More Aggressive Enforcement, FATCA Effective

Recording of a 110-minute CPE/CLE webinar with Q&A


Conducted on Thursday, June 19, 2014

Recorded event now available

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Program Materials

This webinar will provide tax professionals and counsel with a review, by an experienced panel of Canadian tax advisor/attorneys, of key recent and emerging corporate tax developments for U.S. companies. The panel will outline areas where U.S. and Canadian businesses must update tax compliance and planning.

Description

Over the past few years, developed countries have adopted increasingly aggressive policies to combat tax evasion and tax planning perceived as abusive or inappropriate. Witness, in the U.S., the rapidly approaching FATCA compliance deadline and, internationally, the OECD’s Base Erosion and Profit Shifting or “BEPS” initiative.

As part of this broader trend, Canada has heightened focus on suspect tax practices, both in enforcing existing tax laws and in adopting new or amending existing laws targeted to potentially abusive tax planning or evasion.

The focus on U.S. company taxation continues with the phasing in of 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 the attention of businesses operating on both sides of the border.

Canada's most high-visibility actions include entering into a new intergovernmental agreement with the United States, increased Canada Revenue Agency (CRA) focus on transfer pricing, significant new court rulings dealing with transfer pricing disputes, significant changes to Canada’s thin capitalization rules, and proposed new anti-treaty shopping initiatives. 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 for tax professionals and attorneys into the most recent, relevant developments in corporate tax in Canada that affect U.S. companies.

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Outline

  1. FATCA and new Canada–United States IGA
    1. Highlights of the IGA
    2. New Canadian implementing legislation
    3. Draft CRA guidance
  2. Transfer pricing issues for U.S. companies
    1. New CRA initiatives
    2. Recent court rulings
  3. Change to Canada’s Thin Capitalization Rules
    1. Extension to trusts, partnerships and branches
    2. Deemed dividend treatment of disallowed interest
    3. New budget proposals and implications for financing Canadian subsidiaries
  4. New Anti-Treaty Shopping Rule
    1. Implications for inbound investment
    2. Impact on U.S. companies
    3. Comparison with similar international proposals (e.g. BEPS initiative)

Benefits

The panel will address the tax implications and potential pitfalls arising from new Canadian tax developments, including:

  • The Canada-United States IGA
  • New transfer pricing cases and initiatives
  • Updates to Canada’s thin capitalization regime affecting U.S. companies and their Canadian subsidiaries
  • The anti-treaty shopping proposals contained in the last budget

Faculty

Jonathan Garbutt
Jonathan Garbutt

Barrister and Solicitor
Garbutt Tax Law

Mr. Garbutt's practice covers general tax planning and tax minimization, M&A tax matters, international...  |  Read More

Carl Irvine
Carl Irvine

Principal
McMillan

Mr. Irvine provides advice to both Canadian and foreign clients on all aspects of domestic and international tax...  |  Read More

Michel M. Ranger
Michel M. Ranger

Tax Partner
McMillan

Mr. Ranger advises clients on a wide range of domestic and international taxation matters and has specialized...  |  Read More

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