4th Cross-Border Personal Tax Planning

Cover all your bases and avoid excess taxation
Date: May 26 & 27, 2015
Location: Toronto
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Highlights

Cross-border estate planning strategies

Overview of the U.S. estate tax structure

Critical tax planning issues for U.S. citizens in Canada

Latest tax issues affecting non-resident investors in U.S. real property

The U.S.-Canada tax treaty protocol

Tax planning for Canada-U.S. employment transfers

Tax implications of insurance

Tax planning for your cross-border family business

Faculty

FACULTY
COURSE LEADERS
Jonathan Garbutt, Dominion Tax Law
Jonathan N. Garbutt is a Barrister & Solicitor at Dominion Tax Law. He practices all aspects of Canadian income tax law: personal & corporate, planning as well as litigation.
Martin J. Rochwerg, Miller Thomson LLP
Martin J. Rochwerg is a Partner at Miller Thomson LLP. He provides advice on tax planning, estate planning, and succession planning to family business, wills and trusts.
CO-LECTURERS
Ron Choudhury, Aird and Berlis LLP
Ron Choudhury is a Partner at Aird and Berlis LLP. His practice focuses on all aspects of domestic and international tax.
Michael Domanski, Honigman Miller Schwartz and Cohn LLP
Michael W. Domanski is a Partner at Honigman Miller Schwartz and Cohn LLP. His practice focuses on international tax matters and alternative risk financing arrangements.
Sunita Doobay, Tax Chambers LLP
Sunita D. Doobay is a Partner at TaxChambers LLP. She has over 20 years of tax experience in tax controversy and has been advising shareholders and their companies on cross-border taxation and succession planning.
Abigail Kan, McGovern Hurley Cunningham LLP
Abigail Kan is Tax Principal at McGovern, Hurley, Cunningham, LLP with over 20 years of tax experience between public practice, industry and the CRA.
Greg Kanargelidis, Blake Cassels & Graydon LLP
Greg Kanargelidis is a Partner at Blake Cassels & Graydon LLP. His practice embraces all areas of international trade, customs and commodity tax.
Peter Megoudis, Deloitte LLP
Peter Megoudis is a Partner with the Global Employer Services Group of Deloitte LLP. He has been extensively involved in cross-border personal tax planning for the past 15 years.
Sabina Mexis, Zeifmans LLP
Sabina Mexis is Director of Tax and Estate Planning at Zeifmans LLP. She has particular expertise advising on cross-border tax planning and trust and estate planning.
Todd A. Miller, McMillan LLP
Todd Miller is a Partner at McMillan LLP. His practice focuses on income tax, with an emphasis on domestic and cross-border matters.
Christine Perry, Keel Cottrelle LLP
Christine Perry is a Partner at Keel Cottrelle LLP. Her practice focuses on cross-border tax and estate planning solutions for high net worth individuals.
David P. Stevens, Gowling Lafleur Henderson LLP
David Stevens is a Partner at Gowling Lafleur Henderson LLP. His practice focuses exclusively on taxation concentrating on corporate tax, personal tax planning and charities.
Vitaly Timokhov, Tax Chambers LLP
Vitaly Timokhov is a Partner, Canadian and Cross-Border Taxation at TaxChambers LLP.
Jason Ubeika, BDO Canada LLP
Jason Ubeika is Partner, U.S. Tax at BDO Canada LLP. His primary focus is the cross-border taxation of individuals and trusts.
Richard M. Wise, MNP LLP
Richard Wise is a Partner specializing in business valuation and financial litigation at MNP LLP. He has more than 35 years of experience performing valuations for corporate, transactional and taxation purposes

Program

COURSE PROGRAM
U.S. Estate Tax Issues for Canadians: Estate Planning Design and Drafting
Clients migrating from Canada to the U.S. and vice-versa should be aware of the key differences of each country’s tax-purpose valuation policies in each country. This session will address the following subjects:

· Fair market value in Canada vs. Fair market value in U.S.

· CRA valuation policies vs. IRS valuation policies regarding shares in family businesses

· Recent valuation-related Tax Court decisions — Canada and U.S.

· Valuation of a beneficiary’s interest in a trust

· Valuation of fractional interests in real estate

Tax Planning for U.S. Citizens in Canada
U.S. citizens in Canada must carefully plan their move in order to ensure compliance with relevant laws and requirements. Adding to the complexity to this planning, is that these individuals often retain property or business interests in the U.S. and still have taxation obligations there. This session explores tax issues and planning opportunities for U.S. citizens in Canada.

Critical tax planning issues for U.S. citizens in Canada

Avoiding double taxation risks: foreign tax credits issues

Tax treaty implications

Disclosure requirements

Tax Effective Cross-Border Will Planning
While many wills are straightforward, there are intricate tax strategies that come into play in cross-border will planning involving beneficiaries, assets, trustees in different jurisdictions. This session covers efficient financial, legal and taxation issues involved in cross-border will drafting and how to ensure you cover all your bases and avoid excess taxation.

U.S. tax-saving opportunities in will planning

Tax effectively addressing issues in different jurisdictions

Changes to U.S. law affecting will planning

Post mortem impact that U.S. taxes have on estates, trusts and beneficiaries

Tax Implications of Canadians Buying, Selling and Renting U.S. Real Estate
Non-residents must be aware of the tax consequences of buying selling and renting U.S. real estate in order to take advantage of tax planning opportunities and to avoid paying excess taxes. This session will examine the latest tax issues affecting non-resident investors in U.S. real property.

Tax rules applicable to non-residents investing in U.S. real estate

Pros and cons of various ownership structures involving non-residents

Minimizing tax liability on rental income and capital gains

Tax considerations for Canadians owning U.S. rental properties

Estate tax law and U.S vacation homes

The U.S.-Canada Tax Treaty Protocol: Impacts & Opportunities
The Canada-US Tax Convention has been revised a number of times since 1980. The Fifth Protocol included important changes that affect cross-border estate planning and business structures in such areas as international investment, provision of services and stock options. This presentation will provide an overview of its impact and look at tax planning opportunities in light of these changes.

Residency and limitations on benefits under the treaty

Tax consequences of migration

Exemption of certain income under the treaty

RRSPs and pensions

Use of hybrid entities

Trusts & Estate Planning For U.S. Beneficiaries
The inclusion of one or more beneficiaries who are U.S. citizens or residents further complicates the tax considerations in your estate planning process. This session examines the tax implications for such an arrangement and how to plan for them in order to minimize tax.

Impact of U.S. beneficiary on the estate freezes

Implications for Canadian trusts and holding corporations

U.S. transfer tax and income tax considerations

Compliance and reporting obligation issues

Insurance Choices & Tax Implications
Estate and personal tax plans typically do not contemplate the life insurance needs of business owners or high net-worth individuals. This discussion will focus on the design and tax treatment of more innovative insurance programs that can be used in cross-border personal tax planning purposes as well as some of the key cross border tax considerations.

Life Insurance and U.S. estate tax

Use of irrevocable life insurance trusts

Emigrating from Canada with a Canadian issued policy

Immigrating to Canada with a foreign issued policy

Life insurance and valuation of private company shares

Foreign beneficiaries of Canadian policies

Cross-Border Employment Transfers
This session will provide you with an understanding of best practices for facilitating tax compliance and for averting tax problems related to employees on cross-border assignments.

Designing a tax-effective cross-border employee relocation program

Tax equalization and tax protection programs

Tax issues for managing expatriate costs

Planning compensation for cross border executives (stock-based compensation, employee benefits, deferred compensation programs)

Payroll compliance issues

Import Duty and Sales Tax Issues for New Residents of Canada
When an individual moves to Canada, whether permanently or temporarily, there are a number of customs and commodity tax implications relating to the importation of the new resident's personal effects. This presentation will outline:

Customs duties and commodity taxes payable on, and other regulatory requirements respecting, the importation of typical personal effects

Exemptions available to avoid the imposition of customs duties and commodity tax

Properly structuring the move to achieve positive results

Considering customs and commodity tax issues in combination with immigration issues

Special rules that apply to certain types of personal effects

The Cross-Border Conundrum: Can Canadian Insurance Create Problems?
The integration of life insurance and trusts can result in powerful, tax-efficient vehicles for the achievement of estate planning objectives. However, in cross border situations, care must be taken when structuring the ownership and beneficiary designation to ensure the policy will achieve the desired results. This presentation will look at pitfalls in Canadian insurance planning in cross border circumstances.

When Canadian insurance can create U.S. problems

Sources of U.S. issues

Planning considerations to avoid problems

Canadian tax traps to avoid

Ownership transfer issues

Family Law Act treatment of insurance proceeds

Insurance ownership by trust

Multimedia Presentations

MULTIMEDIA PRESENTATION
U.S. estate tax issues for Canadians: Estate planning design and drafting
Jim Yager
KPMG LLP
Trusts and estate planning for U.S.beneficiaries
Sabina Mexis
Deloitte & Touche LLP
Canadian & U.S. expatriation rules
Peter Megoudis
Deloitte & Touche LLP
Tax planning for Canadians opening a business in the U.S.
Stanley Abraham
The U.S. Tax Group Inc.
International wealth and tax planning
James A. Hutchinson
Miller Thomson LLP
Residency issues: Qualifying for Canadian non-residency
Grace Chow
Cadesky and Associates LLP
Tax planning for new immigrants and returning residents
Lorne H. Saltman
Cassels Brock & Blackwell LLP
U.S. Income tax planning: Recent developments
Chris Chan
PricewaterhouseCoopers LLP
U.S. Complex filings, voluntary disclosures, and expatriation
Peter Megoudis
Deloitte & Touche LLP
Workshop: Tax effective estate planning for the international client: Use of trusts
M. Elena Hoffstein
Fasken Martineau DuMoulin LLP
U.S. Estate tax issues for Canadians: Estate planning design and drafting
David P. Stevens
Gowling Lafleur Henderson LLP
U.S. Gift tax regime: New U.S. tax rules impacting gift tax planning
Michael Pereira
KPMG LLP
Tax-effective cross-border will planning
Rahul Sharma
Miller Thomson LLP
Tax implications of Canadians buying, selling and renting U.S. real estate
Greg Papinko
PricewaterhouseCoopers LLP
Canadian & U.S. expatriation rules
Kristina Soutar
Thorsteinssons LLP
Trusts and estate planning for U.S. beneficiaries
Christine Perry
Keel Cottrelle LLP
The cross-border conundrum: Can Canadian insurance create problems?
Glenn M. Davis
Glenn M Davis Insurance and Estate Consulting
Insurance choices & their tax implications
Joël Campagna
Manulife Financial
Workshop: Tax planning for snowbirds retiring in the U.S.
Alpesh Joshi
Alpesh Joshi CA Professional Corporation
Tax planning for Canadians opening a business in the U.S.
Dan Lundenberg
Grant Thornton LLP
The Canada-U.S. tax convention
Michael W. Domanski
Honigman Miller Schwartz and Cohn LLP
International wealth & tax planning
Peter C. Myers
PricewaterhouseCoopers LLP
Incorporating a holistic approach to income splitting
Don Nilson
Nilson & Company AFT TRIVEST Management Inc.
The use of trusts in estate planning
Nicolas P. Smith
Legacy Tax + Trust Lawyers
Principal tax considerations in business succession alternatives
Michael C. Morgan
Chappell Partners LLP

Participants

Aird and Berlis LLP

BDO Canada LLP

Blake Cassels & Graydon LLP

Deloitte LLP

Dominion Tax Law

Gowling Lafleur Henderson LLP

Honigman Miller Schwartz and Cohn LLP

Keel Cottrelle LLP

McMillan LLP

McGovern Hurley Cunningham LLP

Miller Thomson LLP

MNP LLP

Tax Chambers LLP

Zeifmans LLP

Who should attend

Lawyers in Tax Planning, Lawyers in Estate Planning, Financial Planners, Investment Planners and Tax Accountants who want to expand their knowledge area or keep up-to-date in this field

Price

Price list:-
  • Course: $1975
  • Webcast only : $1575
  • Webcast and Proceedings : $1874
  • Course and Proceedings : $2274
  • Proceedings Only: $799
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Additional Information

REGISTRATION:
To reserve your place, call Federated Press toll-free at 1-800-363-0722. In Toronto, call (416) 665-6868 or fax to (416) 665-7733. Then mail your payment along with the registration form. Places are limited. Your reservation will be confirmed before the event.
LOCATION:
Courtyard by Marriott Downtown Toronto, 475 Yonge Street, Toronto, ON, M4Y 1X7, (800) 847-5075
CONDITIONS:
Registration covers attendance for one person, the supplementary course material as described in this document, lunch, morning coffee and refreshments during breaks are provided for registered duration. The proceedings of the event will be captured on audio or video. Multimedia proceedings with all slides and handouts can be purchased separately on a CD-ROM which will also include the event material.
This event is being webcast. A camera will capture the person making the presentation. A camera may also capture the registration desk. The public webcast only includes the presentation. By registering, you agree to waive any recourse against Federated Press as a consequence of the webcast of your presence at the event. Please enquire with onsite hosts if you wish to ensure that your seat is outside the scope of the webcast.
Workshops are not covered in webcast.
TIME:
Registration begins at 8:00 a.m. The morning sessions start promptly at 9:00.
CANCELLATION:
Please note that non-attendance at the event does not entitle the registrant to a refund. In the event that a registrant becomes unable to attend following the deadline for cancellation, a substitute attendee may be delegated. Please notify Federated Press of any changes as soon as possible. Federated Press assumes no liability for changes in program content or speakers. A full refund of the attendance fee will be provided upon cancellation in writing received 13 days prior to event date. No refunds will be issued after this date. Please note that a 15% service charge will be held in case of a cancellation.
DISCOUNT:
Federated Press has special team discounts. Groups of 3 or more from the same organization receive 15%. For larger groups please call Sandra Frattolillo at 1-800-363-0722, ext. 223 to get more information.
PAYMENT:
Payment must be received seven days prior to the event date.