U.S.-Canada Cross Border Corporate Tax Challenges
Planning and Compliance Strategies Given Latest Guidance and Regulation Changes
Recording of a 110-minute CPE/CLE webinar with Q&A
This CLE course 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.
- 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
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.
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Barrister and Solicitor
Garbutt Tax Law
Mr. Garbutt's practice covers general tax planning and tax minimization, M&A tax matters, international... | Read More
Mr. Garbutt's 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.Close
He manages a wide range of transfer pricing engagements for clients in industries ranging from technology to... | Read More
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.Close
He is assigned to the firm's tax and trusts group, where his practice focuses on general corporate income tax law for... | Read More
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.Close