9th Tax Planning for the International Client

Get the latest from top tax experts on how to reduce foreign and Canadian taxes significantly
Date: November 12 & 13, 2015
Location: Toronto
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Highlights

Hear how you can cross international borders without paying more tax than you have to

Examine criteria used by the tax authorities to determine residency status and what steps should be taken to become a non-resident for tax purposes

Look at ways to minimize departure tax

Explore tax planning for retiring abroad that will enable you to take advantage of opportunities

Get an overview of the tax issues and tax planning opportunities for new immigrants working and living in Canada

Explore strategies for the use of trusts in migration tax planning

Examine the issues involved in disposing of Canadian property after emigrating from Canada

Faculty

FACULTY
COURSE LEADERS
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.
Ryan Morris, WeirFoulds LLP
Ryan Morris is a Partner at WeirFoulds LLP. His practice focuses on various areas of domestic and international taxation.
CO-LECTURERS
Ron Choudhury, Miller Thomson LLP
Ron Choudhury is a Partner at Miller Thomson LLP. He practices in the tax and estates area and advises clients on all aspects of corporate income tax and GST/HST.
Grace Chow, Cadesky and Associates LLP
Grace Chow is a founding Partner at Cadesky and Associates LLP. She has specialized in Canadian and international tax, with a concentration on estate planning and trusts for the past 20 years.
Michael Domanski, Honigman Miller Schwartz and Cohn LLP
Michael Domanski is a Partner at Honigman Miller Schwartz and Cohn LLP. His practice focuses on international tax matters and alternative risk financing arrangements.
Romana Fabicka, BDO Canada
Romana Fabicka is Senior Manager, U.S. Tax at BDO Canada LLP. She has specialized in Canada-U.S. cross-border taxation since 2003, with focus on individual, trust and estate tax matters.
Jonathan N. Garbutt, Dominion Tax Law
Jonathan N. Garbutt is Barrister & Solicitor of Dominion Tax Law. He practices Canadian income tax law, including matters of general tax planning.
Abigail Kan, McGovern Hurley Cunningham LLP
Abigail Kan is Tax Principal at McGovern Hurley Cunningham LLP. She practices tax in the resource, financial institution and consumer market sectors.
David Lesperance, Lesperance & Associates
David S. Lesperance is Managing Partner of Lesperance & Associates. He specializes in helping High Net Worth individuals acquire residency or citizenship to fulfill personal, tax or estate-planning objectives.
Todd A. Miller, McMillan LLP
Todd A. Miller is a Partner at McMillan LLP. His practice focuses on income tax, with an emphasis on domestic and cross-border financing transactions (public and private).
David P. Stevens, Gowling Lafleur Henderson LLP
David P. Stevens is a Partner at Gowling Lafleur Henderson LLP. He practises taxation law with a focus on corporate tax, personal tax planning and charities.
Vitaly Timokhov, TaxChambers LLP
Vitaly Timokhov is a Partner at TaxChambers LLP. He practices exclusively in Canadian federal income taxation and tax planning.
Richard M. Wise, MNP LLP
Richard M. Wise is a Partner at MNP LLP. He has more than 35 years of experience performing valuations for corporate, transactional and taxation purposes, and writes and lectures extensively across Canada and the U.S.

Program

COURSE PROGRAM
Residency Issues: Qualifying for Canadian Non-Residency
International private clients are facing increased tax planning challenges. A key starting point centres around the concept of residency. This session will examine criteria used by the tax authorities to determine residency status and the steps that should be taken to sever ties with Canada for tax purposes.

Determining whether to become a non-resident for tax planning purposes: pros and cons

Determining residency status: criteria used for determining residency in U.S. & Canada

Becoming a non-resident for tax purposes: steps for properly severing ties with Canada

Issues to be addressed when terminating Canadian residency

Minimizing Departure Tax: Deemed Dispositions of Property
When a taxpayer ceases to be resident in Canada, the ITA deems the taxpayer to have disposed of, and then reacquired their property immediately before the cessation of residence, giving rise to departure tax. This session will examine steps to take prior to your departure, including tax planning opportunities and practical tips to minimize departure tax costs.

Tax planning to minimize departure tax: strategies for sheltering capital gains

Property excluded from departure tax

Final filing requirements with the Canadian Revenue Agency

Departure tax security: deferring the payment of tax

Tax Planning for New Immigrants and Returning Residents
Newcomers to Canada must carefully plan their move in order to ensure compliance with relevant laws and requirements. This includes keeping track of and reporting the Fair Market Value of their assets when becoming a resident of Canada. Complex issues can arise in determining the fair market value of assets considering the respective valuation rules under the Canadian tax system and the other country’s tax system. This session will provide an overview of the valuation-related issues and tax planning opportunities for new Canadian immigrants.

Fair market value: Income Tax Act Canada vs. U.S. Internal Revenue Code

CRA policy vs. IRS policy on fair market value determination and reporting

Taxable Canadian property

Fractional interests in real estate

Restricted shares, stock options

Effect of embedded taxes on newcomer’s holding company assets and value of issued shares

Canada-U.S. Tax Treaty considerations

Valuation planning opportunities for new immigrants and returning residents

Canadian Repatriation Strategies
This presentation will discuss pre-repatriation, repatriation and post-repatriation tax planning, including possible scenarios resulting in a tax win.

Reversing the deemed disposition of capital property

Basis bump of assets upon re-establishing Canadian residency

Reestablishing residency: tax minimization strategies

Reversing deemed dispositions of capital property on earlier departure upon return as resident

Roll-over of an IRA and or 401k funds to an RRSP

Collection of U.S. social security for U.S. citizens while a U.S. non-resident alien

Import Duty and Sales Tax Issues for Transferees to Canada
When migrating to or from Canada, there are a number of customs and commodity tax implications of moving personal effects of the transferee across the border. 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 U.S.-Canada Tax Treaty: Impacts and Planning Opportunities
The Canada-U.S. Tax Convention can have a significant effect on the tax treatment of transactions involving the two countries. This presentation will provide an overview of its impact and look at potential tax planning opportunities.

Rules dealing with corporate residence / limitation on benefits provisions

Holding company and other structuring techniques

Financing and repatriation planning

Foreign tax credit and withholding tax consequences

Taxable Canadian Property
Non-residents of Canada are subject to Canadian capital gains tax or income tax on a disposition of taxable Canadian property TCP, unless a treaty exemption is available. This session will examine issues involving taxable Canadian property.

Non-residents disposing of TCP: substantive rules

Section 116 certificate procedure

Managing risk under the rules

Exemptions from Canadian tax under a tax treaty

Recent Tax Treaty Developments: Impact and Planning Opportunities for International Client
This session will look at recent Canadian tax treaty developments and their implications for tax planning for international clients.

Latest tax treaty developments

Tax planning opportunities for the international client

Preparing for developments on the horizon

Exposure to the U.S. Gift & Estate Tax Regime
The U.S. estate and gift tax has undergone significant changes over the past few years and there are more changes in store for the future. The changes offer a window of opportunities for those who take appropriate action, but a minefield for those who don’t. The presentation will cover:

The evolving U.S. estate and gift tax: then, now and tomorrow

Mixed marriages: U.S. citizen married to a Canadian

Tax issues for Americans in a Canadian estate freeze

How Canadians can avoid U.S. estate and gift taxes

Multimedia Presentations

MULTIMEDIA PRESENTATION
Tax planning for new immigrants and returning residents
Lorne H. Saltman
Cassels Brock & Blackwell LLP
U.S. Income tax planning
Brian Dunkel
PricewaterhouseCoopers LLP
Tax effective estate planning for the international client: Use of trusts
Martin J. Rochwerg
Miller Thomson LLP
Creating offshore structures
Elie Roth
Davies Ward Phillips & Vineberg LLP
U.S. Non-filers
Peter Megoudis
Deloitte & Touche LLP
U.S. Complex filings, voluntary disclosures, and expatriation
Peter Megoudis
Deloitte & Touche LLP
Canadian & U.S. Expatriation rules
Brent Pidborochynski
Thorsteinssons LLP
Taxable Canadian property
Maureen Berry
Goodmans LLP
Exposure to the U.S. gift & estate tax regime
Jim Yager
KPMG LLP
Tax effective cross-border will planning
Martin J. Rochwerg
Miller Thomson LLP
U.S. Estate tax issues for Canadians: Estate planning design and drafting
Christine Perry
Keel Cottrelle LLP
Tax implications of Canadians buying, selling and renting U.S. real estate
Greg Papinko
PricewaterhouseCoopers LLP
Trusts and estate planning for U.S. beneficiaries
Christine Perry
Keel Cottrelle LLP
Succession planning in the family law context
Martin J. Rochwerg
Miller Thomson LLP
Tax-efficient use of life insurance
Nathan Wright
Nathan Wright Law Professional Corporation
International wealth and tax planning
James Hutchinson
Miller Thomson LLP
The use of trusts in estate planning
Michael Morgan
Chappell Partners LLP
U.S. Gift tax regime: New U.S. tax rules impacting gift tax planning
Michael Pereira
KPMG LLP
Charitable gift planning
Peter A. Wouters
Empire Financial Group
Estate planning for spouses & couples (and related litigation issues)
Melanie McDonald
Borden Ladner Gervais LLP
Tax planning for snowbirds retiring in U.S.
Peter Megoudis
Deloitte LLP
The U.S.-Canada tax treaty protocol
Andrew Stirling
McMillan LLP
Insurance choices & tax implications
Joel Campagna
Manulife Financial
The cross-border conundrum: Can Canadian insurance create problems?
Glenn M. Davis
Glenn M Davis Insurance and Estate Consulting
Implications for Canadians: US real estate tax
Greg Papinko
PricewaterhouseCoopers LLP

Participants

BDO Canada

Blake Cassels & Graydon LLP

Cadesky and Associates LLP

Dominion Tax Law

Gowling Lafleur Henderson LLP

Honigman Miller Schwartz and Cohn LLP

Lesperance & Associates

McMillan LLP

McGovern Hurley Cunningham LLP

Miller Thomson LLP

MNP LLP

TaxChambers LLP

WeirFoulds LLP


Who should attend

Lawyers in Tax Planning; Lawyers in Estate Planning; Financial Planners; Investment Planners

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.