Taxation of Corporate ReorganizationsNovember 30, 2017Courtyard by Marriott Toronto Downtown475 Yonge St, Toronto, ON M4Y 1X7
Conference no 1
9:00 to 11h15 including 15-minutes break (10:15 to 10:30)
This presentation discusses advanced planning issues related to the surplus stripping rules, including:
Jesse Brodlieb is a Partner in Dentons' Taxation group. His practice includes advising clients on international and domestic income taxation matters, with a focus on corporate taxation. He provides advice on establishing and reorganizing corporate structures in a tax-efficient manner. He also advises Canadian charities on obtaining and maintaining status as a registered charity. Jesse frequently comments and presents on private client tax issues.
Megan Seto is an associate in Dentons? Toronto office and a member of the Firm?s Tax group. In her practice, Megan works with taxpayers in a variety of matters involving the Canada Revenue Agency, focusing on cross-border and international tax and tax disputes. She advises businesses and their shareholders on the tax aspects of mergers and acquisitions, corporate reorganizations, and financing. Megan also assists clients on non-resident tax issues, negotiating and responding to tax audits, preparing objections and settlement, and litigation.
Conference no 2
11:15 to 12:15
This presentation will explore the various provisions of the Income Tax Act that permit the creation, liquidation, incorporation and merger of partnerships on a tax-deferred basis and will examine potential opportunities and pitfalls that may arise in the context of partnership reorganizations.
Partnerships are frequently used as business or investment vehicles for various tax and non-tax reasons. The provisions of the Income Tax Act governing the taxation of partnerships include various specific rules that facilitate partnership reorganizations. This session will explore the provisions of the Act which, alone or in combination, allow the transfer of assets to a partnership and the liquidation, incorporation and merger of partnerships, and the consequences of their application on the various participants in the reorganization. The presentation will also review important administrative positions issued by the Canada Revenue Agency that impact the reorganization of partnerships. Finally, this session will examine potential opportunities and pitfalls that may arise in the context of partnership reorganizations.
Genevieve Lille is a lawyer in the tax practice of PWC Law LLP, with experience advising Canadian domestic and multinational clients on all aspects of Canadian corporate taxation. She is a member of PwC?s Tax Dispute Resolution group and regularly assists clients in their dealings with the federal and provincial tax authorities.
Geneviève is a recognized expert on Canadian partnership taxation. She co-authored the best-seller Understanding the Taxation of Partnerships, published by Wolters Kluwer, 7th edition, 2017. She holds a civil law degree and a common law degree from McGill University and is a member of the Quebec and Ontario Bars.
12:15 to 1:15
Conference no 3
1:15 to 2:00
This session will review recent development affecting to the taxation of partnerships and their members, including recent court cases dealing with the taxation of limited partnership income and losses, and legislative developments affecting professional partnerships and partnership reporting. The presentation will also review selected recent administrative positions issued by the Canada Revenue Agency and the Quebec Revenue Agency and discuss the practical issues that may arise therefrom for partnerships and their members or investors.
Conference no 4
2:00 to 2:45
This presentation will focus on how restructuring affects not only the value of the business, but also the wealth of individual shareholders. The presentation will address common hurdles or challenges and some solutions in resolving valuation issues.
Neil Maisel ? BComm, CPA, CA, CBV, Partner
Neil Maisel is a partner in the Valuations | Forensics | Litigation Group at Crowe Soberman. Neil plays an integral part in the firm?s leadership as the firm?s Ethics Officer. For 16 years he also served as a member of the Management Committee.
Neil brings a wealth of experience, having worked in the tax and assurance and advisory practices. For the last 28 years, Neil?s practice focused on matrimonial matters, shareholder disputes, corporate and commercial damage claims, business valuations and other litigation support.
Neil is the vice president of Due Diligence Inc. (DDI), a corporation devoted to the detection, prevention and investigation of occupational fraud, waste and abuse. In this role, Neil provides both financial and forensic investigative and accounting services to the commercial, corporate, financial, government and legal sectors.
Neil enjoys lecturing on a number of topics, some of which are accredited presentations, and has authored numerous articles on topics including business valuation, litigation, family law and tax matters.
2:45 to 3:00
Conference no 5
3:00 to 4:30
This presentation will outline the techniques and strategies for addressing sales tax issues in corporate reorganizations, joint ventures and partnerships. The presentation will include a review of the new GST/HST ?investment limited partnership? rules and will highlight tips and technical traps that are critical to understand in sales tax planning for clients.
Neil Bass is a highly experienced practitioner in tax litigation and commodity taxation, including goods and services tax and harmonized sales tax (GST/HST), provincial sales tax (PST) and international customs duties. He has extensive experience in dealing with various taxation authorities and has represented clients before the Canadian International Trade Tribunal, the Tax Court of Canada, the Federal Court and Federal Court of Appeal as well as before provincial courts.
He has significant experience in the real estate and development sector, financial services, corporate reorganizations, mergers, acquisitions and cross-border transactions. Neil is also experienced in alternative dispute resolution and litigation.
Neil served on the Canadian Bar Association/Canadian Institute of Charter Accountants Joint Legislation Review Committee that reviewed the draft legislation that amended the Canadian Excise Tax Act.