Tax Issues for Commercial Practitioners 2015
Course Date: November 27, 2015
Total: 5h 29min
Course Date: November 27, 2015
Welcome and Introduction
David Christian — Thorsteinssons LLP, Vancouver
I. Corporate Taxation: An Overview
- nature of corporate taxation
- taxation of different sources of income
- corporate tax deferrals
- theory of integration
David Christian — Thorsteinssons LLP, Vancouver
II. Corporate Reorganizations
A. Transfer of Property to a Corporation
- which sections of the Income Tax Act can you use?
- requirements of the various sections
- valuation and price adjustment clauses
- share rights and restrictions
Stephanie J. Daniels — Farris, Vaughan, Wills & Murphy LLP, Vancouver
Networking Break
B. Corporate Distributions
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forms of distributions
-
taxation of different distributions
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owner-manager considerations
Soraya Jamal — Blake, Cassels & Graydon LLP, Vancouver
C. Mergers of Corporations
- tax considerations in business acquisitions
- amalgamations
- wind-ups
Greg Hollingsworth — Lawson Lundell LLP, Vancouver
D. Divisive Reorganizations
- overview of s. 55
- related person reorganizations
- butterfly reorganizations
- purifications, splits, and spins
Alexander Demner — Thorsteinssons LLP, Vancouver
Lunch (on your own)
III. Anti-Avoidance Rules
- surplus stripping
- shareholder benefits
- conferral of benefits
- attribution rules
- GAAR
Michael Coburn — Fasken Martineau DuMoulin LLP, Vancouver
Networking Break
IV. Partnership Taxation
- creating a partnership: tax considerations
- computing the taxable income of a partnership
- taxation of the partners: allocating and distributing partnership income
- partnership losses: negative cost-base, the at-risk rules, and the tax shelter investment rules
- reorganizations and alterations to a partnership
- cross-border tax issues
- termination and dissolution of a partnership
Ron Dueck — Farris, Vaughan, Wills & Murphy LLP, Vancouver
V. Defensive Tax Practice
- what is professional negligence?
- frequent causes of concern
- prudent practices
- reporting errors
- rectifying errors
Tim Clarke — Moodys Gartner Tax Law LLP, Vancouver
Closing Remarks
David Christian — Thorsteinssons LLP, Vancouver
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Paper: Basic Legal Principles and Base Tax Rates
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