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

Conducted on Wednesday, October 6, 2010

Recorded event now available

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Program Materials

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.


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.



  1. Recent developments in Canadian tax policy and regs
    1. CRA policy statements on entities and entity formation
    2. Written position and changes in stance toward hybrid entities
        1. Important remaining questions for taxpayers about post-protocol years
    3. Interpretive guidance on limitation on benefits regs
    4. Reg changes on U.S. taxpayer sales of shares in Canadian companies
    5. Proposed reg revisions for CFCs and foreign trusts
  2. Transfer pricing issues for U.S. companies
    1. Recent court rulings
    2. Pending changes in transfer pricing guidelines for multi-nationals
  3. Review of important aspects of Fifth Protocol to tax treaty
  4. 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


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.


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

Merv Edwards
Merv Edwards

Managing Director
Ceteris Canada

He manages a wide range of transfer pricing engagements for clients in industries ranging from technology to...  |  Read More

Duane Milot
Duane Milot

Cassels Brock

He is assigned to the firm's tax and trusts group, where his practice focuses on general corporate income tax law for...  |  Read More

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