Commodity tax symposium 2018

Stay up-to-date on critical indirect tax issues and network with other indirect tax professionals at Canada’s largest and longest-running indirect tax event.

Event Details

Location and date:
Ottawa October 15-16, 2018

Keep your tax team up-to-date on the latest strategies to deal with tax changes in Canada. Learn from Canadian experts and maximize your investment by networking with other commodity tax professionals at this popular event, back for the 38th year in a row.

The 2018 CTS program will consist of in-depth technical sessions, practical issue identification and topic analysis, plus engaging keynote speakers who will share relevant insights about the impact of policy and legislation on your practice.

Virtual conference option

Can’t make it to Ottawa? Attend virtually. Listen to speakers, see the conference and follow PowerPoint presentations in real time. All you need is a desktop computer, laptop or tablet, plus speakers and high-speed Internet.

2019 Call for submissions

October 23-24, 2019 (Post-Conference Workshop on October 25, 2019)
The Westin Ottawa | Ottawa, ON

CPA Canada is planning for the 2019 Commodity Tax Symposium, and we invite you to submit your suggestions for session and/or technical paper topics.

Join the ranks of Canada’s top indirect tax talent and share your expertise to help guide others.

Submissions from industry leaders, tax practitioners and government professionals are welcome, and will be presented to the advisory committee. Preference is given to technical papers. The deadline is January 31, 2019

For detailed requirements, terms and conditions, and to submit your paper, please contact Joanna Boutasis.

View the agenda


2017 Normand Guérin Award

Congratulations to Andrew Azmudeh, the winner of the 2017 Normand Guérin award. The award is presented by Deloitte LLP for an outstanding contribution to the advancement of commodity tax studies.

2018 Normand Guérin Award

Congratulations to Thomas Brook and Emily Stanhope, the winners of the 2018 Normand Guérin award. The award is presented by Deloitte LLP for an outstanding contribution to the advancement of commodity tax studies. Brook and Stanhope won for their paper “A Guide to Insurance Premium Taxation in Canada.”

Additional options and pricing may be available. See pricing and registration for more details.


12 (18 with the workshop) CPD hour(s)
Pricing & registration

Topics include:

  • technology and its impact on the management of indirect taxes
  • changes to VDP, investment limited partnership, and drop shipment rules
  • PST essentials
  • recent case law update on indirect taxes
  • updates from the Canada Revenue Agency and the Department of Finance

Who should attend?

  • accounting professionals
  • lawyers
  • consultants
  • academics
  • senior executives
  • professionals who lead internal commodity tax groups for industry or not-for-profit organizations
  • representatives from the CRA, the Department of Finance, and provincial ministries of finance charged with policy and compliance initiatives regarding sales taxes and other indirect taxes

More Details:

Session Descriptions

Early Bird Registration and Welcome Reception
Confederation Foyer
Sponsored by RSM

Registration and Continental Breakfast
Confederation Foyer
Registration sponsored by RSM
Continental Breakfast sponsored by KPMG

Welcome Remarks and Keynote Address
Room: Confederation 2&3
Chantal Hébert, National Affairs Columnist for the Toronto Star
Sponsored by TD Insurance
Chantal Hébert

Presentation of the Normand Guérin Award, Presented by Deloitte
Room: Confederation 2&3

A View From The Top – Indirect Tax Perspectives From Industry Heads of Tax
Room: Confederation 2&3

Moderator: Sania Ilahi, EY
Panelists: Pier Fiorino, Telus Corporation; Olaf Sheikh, BMO Financial Group; Franca Vercillo, Aecon

Indirect taxes continue to evolve at a rapid pace both globally and in Canada, and consumption taxes now account for more than 20% of total tax revenue globally. With advancements in technology and the ability to deliver goods and services cross border, both domestic and international, indirect taxes take on greater levels of complexity and importance. Coupled with this is the increasing reach of tax authorities across borders and the increase in audit activity overall. This panel is a unique opportunity to hear from the heads of tax departments of large entities in Canada as they share their perspectives on key indirect tax issues facing Canadian taxpayers.
Sania Ilahi ; Pier Fiorino ; Olaf Sheikh ; Franca Vercillo

Coffee Break - Exhibits Open
Confederation Foyer
Sponsored by Ryan

Choose one of the following:

Post Quill – The New Era of U.S. State and Local Taxation
Room: Provinces 1

Niki Ford and Drew Hemmings, Baker & McKenzie LLP

This session will (1) review key implications from the recent U.S. Supreme Court ruling in South Dakota v. Wayfair, Inc.; (2); discuss the current status of economic nexus legislation and other measures across the 50 U.S. states; (3) analyze the impact the Wayfair ruling will have on the U.S. retail industry; and (4) debate what’s to come in the new era of U.S. state and local taxation post-Quill.
Nicole Ford ; Drew Hemmings

Just What Is a Cryptocurrency Anyway?
Room: Confederation 2&3

Maryse Janelle, Raymond Chabot Grant Thornton and and Ugo Cloutier, Ugo Cloutier CPA

Cryptocurrency is one of the potential applications of the very innovative blockchain technology. Cryptocurrencies are becoming a reality in the business world and the adequate application of sales taxes is still a grey zone.
In this session, you’ll get a brief overview of the basics of blockchain and cryptocurrencies. Then we’ll move on to the various tax considerations in relation to buying, selling and using cryptocurrencies in transactions. We’ll then cover the subject of cryptocurrency miners, who receive cryptocurrencies in exchange of providing computing power. Finally, we’ll discuss the potential solutions in relation to sales tax problems.

Maryse Janelle ; Ugo Cloutier

Investment Vehicles – Which One to Choose?
Room: Provinces 2

Jadys Bourdelais and Jonathan Ip, EY Law LLP

This presentation will consist of a comparative analysis of the GST/HST and QST treatment applicable to the investment vehicles (i.e. corporation, limited partnership and trust).
The presenters will determine whether an investment vehicle structure is more advantageous than another while elaborating on the applicable rules, including, in respect of each investment vehicle:
• Residency and deemed residency status.
• Registration and ITC/ITRs availability (including Finance Canada proposed legislative amendments to 186 ETA).
• Deeming rules (including 272.1 ETA).
• Financial institution status (LFI, SLFI, SAM calculations) and application of zero-rating provisions.

Jadys Bourdelais ; Jonathan Ip

Networking Lunch
Room: Confederation 1
Sponsored by Felesky Flynn LLP

Choose one of the following:

New Rules Affecting Investment Limited Partnerships – Welcome to the Club!
Room: Confederation 2&3
Danny Cisterna, Deloitte

This session will describe the new rules impacting newly defined “investment limited partnerships” or ILPs and their entrance into the club of other “investment plans” in determining their liability for the provincial component of HST and in applying GST/HST to management and administrative services supplied to them. The session will go over some of the challenges surrounding the determination of whether a partnership fits within the definition of ILP and, if it does, how do the new rules affect it. This session will be of interest to investment structures that use limited partnerships to pool monies from investors and particularly in the area of private equity, venture capital, hedge funds, real estate and oil and gas investments and to those who advise these structures.
Danny Cisterna

Places of Supply and Where to Find Them
Room: Provinces 2

Sabina Han, Fasken Martineau

When is the place of supply not where one would expect? This session will address the place of supply rules for tangible personal property, real property, services, and intangible personal property, and highlight the nuances and common issues. It will also discuss how the place of supply rules interact with other areas of law, such as contracts law (including INCO terms) and sale of goods legislation. Recent developments in case law and administrative policies will be addressed, along with recommendations for avoiding unintended place of supply consequences.
Sabina Han

If You Build It, Tax May Come - PST on Real Property Contracts
Room: Provinces 1

Tracey Osmond, Grant Thornton

Are you responsible for PST reporting for your organization?

In recent years, there have been a number of changes to how provincial sales taxes in British Columbia, Saskatchewan and Manitoba apply to services performed by real property contractors. Mistakes can be costly and these types of services are routinely audited by PST auditors. This presentation will help participants clearly understand the current regulations related to these services and work though examples such as using out of province service providers.

Tracey Osmond

Session Break

Choose one of the following:

There is a New Dealer in Town - An Introduction to the Canadian Cannabis Indirect Tax and Excise Duty Framework
Room: Provinces 1

Beverly Gilbert and Braek Urquhart, Borden Ladner Gervais LLP

Held two days before the legalization of Canada’s recreational cannabis market, this timely session provides a technical overview of the taxation of the production, distribution and sale of cannabis products throughout Canada. This presentation outlines the federal excise duties and GST/HST rules applicable to the recreational and medicinal cannabis markets, and summarizes the various cannabis-related taxes and fees introduced by the provincial and territorial governments. By working through a series of examples, this presentation will help attendees understand how these duties, fees and taxes apply to the various provincial cannabis distribution and retail markets.
Beverly Gilbert ; Braek Urquhart

Of Course It’s Commercial! (Isn’t It?)
Room: Confederation 2&3
Christina Zurowski and Grace Caputo, Grant Thornton

A registrant’s eligibility to recover GST/HST incurred as input tax credits (“ITCs”) may often be taken for granted, especially where the organization is involved in taxable activities (i.e., commercial activities). Recently, there have been situations where a GST/HST registrant’s ability to recover the tax has been questioned despite their apparent involvement in commercial activities. What really determines a person’s ability to claim ITCs? At what point does it start? When does it end? Are there any special provisions that may impact that eligibility?

In this paper/session, we will examine all of these issues and will consider recent CRA decisions and court cases with the goal of providing organizations with the necessary guidance to determine their ability to claim ITCs as it relates to their commercial activities and potential areas of concern.

Grace Caputo ; Christina Zurowski, CPA, CA

Digital Transformation of Tax Authorities - Next Stop: Canada
Room: Provinces 2

Eric Paton, PwC

Not only has technology provided the opportunity for businesses to better manage their indirect taxes, it has also created a significant number of opportunities for governments around the world to obtain information from businesses in new and efficient ways to ensure the proper amount of tax is collected. Satisfying the requirements needed for businesses to comply with government requests can be quite disruptive and the information that is requested can be used in a variety of different ways, not solely for indirect tax purposes.

The purpose of this presentation will be to introduce and discuss the direction that many tax authorities around the world are taking in this digital era so that you are aware of the the options available to the Canadian government to obtain a better level of compliance and to ensure that your business understands where things may be headed and is prepared for what's next.

Among others, topics to be discussed include:

- End to End Indirect Tax Data Management from purchaser to vendor to tax authority
- Mandatory e-Invoicing
- Real time reporting
- Split payments
- Blockchain

Eric Paton

Coffee Break - Exhibits Open
Confederation Foyer
Sponsored by Ryan

Case Law Update
Room: Confederation 2&3
Neil Bass and Angelo Gentile, Aird & Berlis LLP

This year has seen an extraordinary number of significant and precedent- setting decisions in the field of commodity tax. Important decisions in the areas of financial services, real property, place of supply and conduct of the CRA during audits have been issued by various levels of courts in both Canada and beyond.

Neil and Angelo will review the important decisions, discuss their applicability beyond the four corners of the decisions and provide their views on the practical implications to taxpayers and their advisors.

Angelo Gentile

Networking Reception
Confederation I

Breakfast Session: New QST mandatory registration for non-resident suppliers – a discussion with Revenu Québec
Room: Confederation 2&3
Speakers: Patrick Lacombe, Revenu Québec and Jean-François Senécal, Crowe BGK

The speakers will take an in-depth look at the technical and practical implications of the upcoming QST registration and collection requirements for suppliers without physical or significant presence in Quebec. Topics of discussion will include:

- The digital platform definition including illustrative examples;
- Update on Revenu Québec online registration and reporting procedure;
- The situations in which an adjustment or refund of the QST collected from Quebec consumers will be available;
- Insight on the administration of the measure by Revenu Québec;

The presenters will welcome questions at the end of their presentation.

Patrick Lacombe ; Jean-Francois Senecal

Continental Breakfast
Confederation Foyer

Fireside Chat with the Department of Finance
Room: Confederation 2&3
Moderator: Danny Cisterna, Deloitte
Panelists: Phil King, Pierre Mercille, Mark Walsh, Carlos Achadinha and Gervais Coulombe, Department of Finance

Meet the new Director of the Sales Tax division of the Federal Department of Finance and learn about some of the inner workings of Finance and how they consult with stakeholders in the establishment of GST/HST policy. Phil King will be joined by some of his senior team members in addressing questions around Finance’s inner processes, current workings available for public consumption and how stakeholders can impact tax policy.
Danny Cisterna ; Phil King ; Pierre Mercille ; Mark Walsh ; Carlos Achadinha ; Gervais Coulombe

Session Change Break

Choose one of the following:

Agency and Trust Issues
Room: Confederation 2&3
Elena Balkos, KPMG

This session will examine how agency relationships and trusts play into commodity tax, which is generally based on “suppliers” and “recipients”. A general refresher will be provided, along with a consideration of current issues and some recent cases. This session will examine how agency relationships and trusts play into commodity tax, which is generally based on “suppliers” and “recipients”. A general refresher will be provided, along with a consideration of current issues and some recent cases.
Elena Balkos

Analysis and Critique of the New GST/HST Voluntary Disclosure Policy
Room: Provinces

W. Jack Millar, Millar Kreklewetz LLP

Since the introduction of the GST in 1991, Canada has had some sort of Voluntary Disclosures Program (“VDP”) that has provided persons who have not complied with their GST/HST obligations under the Excise Tax Act with an opportunity to come forward to correct their tax affairs. This session discusses the policy rationale behind VDPs and provides a thorough analysis and critique of the major changes to the GST/HST VDP that were announced on December 15, 2017 and came into effect on March 1, 2018
Jack Millar

Networking Coffee Break - Exhibits Open
Confederation Foyer
Sponsored by Ryan

Understanding Tax Administration: CRA’s GST/HST Rulings & Compliance Branch
Room: Confederation 2&3
Phil Nault, Canada Revenue Agency

GST/HST continues to evolve and its relative importance, as a share of total revenue, has increased. CRA will provide insight into the operations of its GST/HST Rulings and Compliance Branch and their recent initiatives.

Danielle Laflèche ; Shashi Fernando

Networking Lunch
Room: Confederation 1
Speaker: Craig McDougall, Felesky Flynn LLP (12:40 - 1:10)

Choose one of the following:

Canadian Sales Tax Registration Requirements
Room: Confederation 2&3
David D. Robertson, EY Law LLP and Stephen J. Rukavina, Clark Wilson LLP

This paper and presentation will comprehensively cover Canadian sales tax registration requirements.

The GST/HST and QST registration requirements will be reviewed in-depth, focusing on the carrying on business test relevant to non-residents. An overview of jurisprudence and CRA administrative policy will be provided. Unique situations will be examined such as non-residents engaged in consignment and leasing transactions. Quebec’s proposed changes to expand the QST registration requirements to certain businesses without any physical or significant presence in Quebec will be discussed.

Registration requirements for BC, Saskatchewan and Manitoba sales taxes will also be examined in-depth, including recent legislative changes.
David Robertson ; Stephen Rukavina

CRAs Priority Rights for Unremitted Amounts
Room: Provinces

Maurice Chiasson, Stewart McKelvey and Jeremy Scott, BDO

Tax Authorities around the world are increasingly vigilant in taking steps to protect their tax bases and taking additional steps to enforce the collection of taxes owing. The Canada Revenue Agency (“CRA”) is no exception.
In recent years, the CRA has been more aggressive in its collection efforts, particularly in relation to funds collected by a taxpayer from third parties for remittance to the CRA. The CRA considers such collected funds to be trust funds. As a result, tax legislation contains special provisions designed to assist the CRA to recover such amounts. The Excise Tax Act (the “ETA”) is no exception to this rule as it contains specific provisions designed to safeguard these trust funds.
The enforcement of these provisions is not without controversy particularly when the rights of other creditors of a tax debtor are taken into consideration. The CRA’s rights in relation to certain such creditors will soon be considered by the Supreme Court of Canada in the Calladus case.
This session will examine the deemed trust provisions contained in the ETA and the issues surrounding its enforcement. Particular emphasis will be placed on the facts in the Calladus case and how the Supreme Court may rule in this matter. We will also review other recent decisions involving the CRA’s defence of its collection powers in relation to the GST/HST.

Maurice P. Chiasson, Q.C. ; Jeremy Scott

Choose one of the following:

The Drop Shipment Rules - Now That We Have Royal Assent, How Do They Work?
Room: Provinces

Randy Schwartz and Dan Weland, PwC

The purpose of the GST/HST drop shipment rules is to provide equal treatment for supplies of goods made by an unregistered non-resident person from outside Canada that are imported into Canada for final consumption and supplies of goods located in Canada made by an unregistered non-resident person for final consumption in Canada. The rules also provide relief in certain circumstances where the goods are ultimately exported or are retained in Canada by a registrant. In the 2016 Federal Budget, the Finance Minister announced that the drop shipment rules would be amended to address perceived gaps in the legislation and longstanding interpretation issues. The full set of rules did not receive Royal Assent until December 14, 2017. In this presentation, Randy and Dan will navigate through the major changes to the drop shipment rules that apply in full to supplies made on or after December 15, 2017.
Randy Schwartz

Turbulent Trade Times: Minimizing Tax on Your Imports and Exports
Room: Confederation 2&3

Moderator: Lisa Zajko, KPMG
Panelists: Todd Mariano, Director - United States of Euroasia Group, Duane McMullen, Director General for International Business Development of Global Affairs, Joy Nott, Former President of IE Canada & Trade and Customs Partner, KPMG and Tobin Richardson, CFO of Erie Architechtural

In light of the “poison pill” sticking points belaboring the NAFTA re-negotiations, the turbulent aftermath of the G7 Summit, and the uncertainty and disruptions challenging cross-border businesses, this panel will discuss the impact on making important business decisions and planning for the future. The panel will moderated by Lisa Zajko, KPMG Trade & Customs Partner and feature Daniel Kerner, of the Eurasia Group, who will provide comments from a geopolitical perspective. The panel will also feature, Joy Nott, KPMG Trade & Customs Partner and former President of the Canadian Association of Importers and Exporters, a Director of Global Trade, and a negotiator from Global Affairs. Following this session, the audience will better understand the likely direction of world events, how companies are reacting and responding, and how they can take practical steps to navigate through the turbulence, take advantage of opportunities, and minimize risks.

Lisa Zajko ; Todd Mariano ; Duane McMullen ; Joy Nott ; Tobin Richardson

Networking Coffee Break - Exhibits Open
Confederation Foyer
Sponsored by Ryan

Technology Table Stakes – Falling Behind Is Not An Option
Room: Confederation 2&3
Susie Cooke, Deloitte

This session looks at an array of the technology changes taking place globally and considers how these may interplay with the world of tax. During this session we will look into the future and discuss the changes currently emerging in the world of tax. We will look at both the prospective short and long term future together.
Susie Cooke

Conference Adjourns

Provincial Sales Tax Essentials – All You Need to Know
Room: Provinces 2

Katherine Xilinas EY Law LLP, Jennifer Muirhead KPMG and Erin Jensen KPMG
Katherine Xilinas ; Jennifer Muirhead ; Erin Jensen, CPA, CA, CPA (IL)

Workshop Registration and Continental Breakfast
Provinces 2 Foyer

Introduction to PST in BC, SK and MB

PST on Tangible Personal Property and Real Property

Coffee Break
Provinces 2 Foyer

PST on Services, Software and Intangibles


Manufacturing Exemptions

PST Registration and Compliance Requirements

Coffee Break
Provinces 2 Foyer

PST Audits, Penalties, Refunds and Appeals

Workshop Adjourns

Thank You to Our Advisory Committee
Richard Taylor (Chair)
Rogers Communications

Wendy Brousseau
McCarthy Tétrault

Danny Cisterna
CPA Canada Commodity Tax Committee

Michèle Clermont
TELUS Communications Inc.

Shashi Fernando
BMO Financial Group

Erin Jensen

Simon Thang
Thang Tax Law

Richard Taylor ; Wendy Brousseau ; Danny Cisterna ; Michèle Clermont ; Erin Jensen, CPA, CA, CPA (IL) ; Simon Thang

Venue[s] and Accommodation[s]


The Westin Ottawa Hotel
11 Colonel By Drive, Ottawa, ON K1N 9H4


The Westin Ottawa Hotel
11 Colonel By Drive, Ottawa, ON K1N 9H4
t.: 613-560-7000

Hotel reservations are the responsibility of the participant. CPA Canada has arranged for special conference rates at the Westin Ottawa.

Traditional Room (single/double)    $259/night
Deluxe Room (single/double)          $309/night
Suites (single/double)                     $384/night
Additional Person                            $40/night

Book online at

Rates available until September 21, 2018, or until the room block is full.

Rates are available three days prior and three days post-conference, subject to availability.

Frequently asked questions:

Group discount:

Organizations sending 10 or more people are eligible for a group discount. Please contact our customer service team for details.

Please note that this discount cannot be combined with other offers. Discount does not apply to workshops.

Networking events

Sunday, October 14, 2018

Welcome reception: Begin the conference with an opportunity to network with attendees prior to the symposium. The welcome reception will take place in the Confederation Foyer (4th floor) of The Westin Ottawa from 4.30pm – 7.30pm.

Monday, October 15, 2018

Networking reception: Following the day’s sessions, join attendees, speakers, sponsors and exhibitors for the CTS networking reception. Enjoy a beverage or two while visiting conference exhibitors and meeting fellow attendees.

What equipment do I need to join the virtual conference?

For a smooth virtual conference experience, ensure that you have:

  • the most current operating system and browser on the device you will use to connect to the virtual conference platform
  • access to high speed/broadband Internet (or 4G/LTE services for mobile/tablet devices); if you are not on high-speed Internet, your video may become patchy at times
  • speakers/headphones to hear the conference speakers
Sponsors & Exhibitors


Deloitte Felesky Flynn KPMG RSM TD logo


DMA TD logo Thomson Reuters logo

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Please contact:

Member Development and Support
Tel: 1-800-268-3793