Event Agenda

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This is the agenda for Pre-Symposium
Pre-Symposium October 22nd, 2019
Early Bird Registration and Welcome Reception

Confederation Foyer

This is the agenda for Day 2
Day 2 October 23rd, 2019
Registration and Continental Breakfast

Welcome Remarks and Keynote Address

Nikolas Badminton, Futurist

Presentation of the Normand Guérin Award, presented by Deloitte

Indirect Tax and Technology Panel

Moderated By: Michelle Tocher, EY

Coffee Beak - Exhibits Open

Concurrent Sessions - choose one of the following:

Technical Paper
Defeating Assessments Using the Reasonable Care Standard - Penalties and Assessment Periods

Penalty assessments, director’s liability assessments and statute barred assessments all have something in common – the efficacy of the assessment typically turns on the conduct of the assessed person.
For example, an assessment for gross negligence penalties can only stand in circumstances where a taxpayer was grossly negligent, a statute barred assessment is only usually only permissible if a taxpayer has acted in a negligent, careless or fraudulent manner and a director’s liability assessment will be defeated if the director acted with due diligence.

The purpose of the session is to explore the distinctions at law between the relevant standard of care associated with successfully defeating each type of assessment. The paper will begin with an overview of the key provisions in the Excise Tax Act and the provincial sales tax acts regarding the conduct related types of assessments followed by a discussion of the relevant standard of care associated with each type of assessment.

Speaker: Kimberley Cook, Thorsteinssons LLP

Kimberley Cook, LLB

An Update on Customs

Today’s global trade environment is undergoing a series of tectonic shifts, creating some of the highest levels of uncertainty in years. With the signing of the United States-Mexico-Canada Agreement on November 30th 2018, the treaty, casually dubbed NAFTA 2.0 encompasses one of the world’s largest free trade zones and over $1.2 trillion in trade. This session will cover the latest updates on the customs and international trade landscape and help you to better understand the forces Canadian companies are facing when planning their international supply chains.

Speaker: Joy Nott, KPMG

Joy Nott

Networking Lunch

Concurrent Sessions - choose from the following:

The New Rules Related to Holding Companies

Speaker: Brent Murray, PwC

Brent Murray

An Update on QST

This session will provide an update on latest QST developments including:
i) New registration requirements for non-residents of Québec;
ii) The repeal of ITR restrictions;
iii) New disclosure requirements in respect of prête-noms (nominees);
iv) New registration requirements for digital platforms offering accommodation; and
v) Other changes, rules, or developments of general interest.

Speakers: Shelley Smith, BDO Canada LLP; Mario Seyer, PwC

Shelley Smith ; Mario Seyer

Session Break

Concurrent Sessions - choose one of the following:

Nexus Issues - Examples from Canada and the US

Provincial and state governments are seeking ways to force non-resident sellers to collect their respective sales taxes on sales to their residents. This is particularly true in the United States following their Supreme Court decision in South Dakota v. Wayfair, Inc. in 2018.

This session will discuss the factors for Canadian businesses to consider in light of Wayfair and provincial sales tax registration requirements using examples. It will also discuss the broader implications of registering to collect a particular sales tax including such issues as gross receipts, income taxes and other legislative requirements.

Rosemary Anderson, Thorsteinssons LLP; Ted Bernert, BakerHostetler

Edward Bernert ; Rosemary Anderson, CPA, CA

Technical Paper
Claim Me if You Can - Financial Institutions and ITCs

Speakers: Danny Cisterna and Simon Douville, Deloitte

Coffee Break - Exhibits Open

Case Law Update

This session will provide an update on the latest important GST/HST cases.

Speakers: D'Arcy Schieman and Al-Nawaz Nanji, Osler, Hoskin & Harcourt LLP

Al-Nawaz Nanji

Networking Reception

This is the agenda for Day 3
Day 3 October 24th, 2019
Continental Breakfast

Managing a CRA Audit

This informative panel discussion will cover a range of topics that provide insight in the operational and risk assessment processes that guide CRA audits. Discussion will focus on increasing understanding of the roles within the compliance spectrum, the relationship between headquarters and tax services offices, the proposal process, $5M referrals and reviews, and how taxpayers can facilitate the audit experience. Other specialized topics that may be addressed include supporting documentation for Input Tax Credits (ITCs), gross negligence penalties, voluntary disclosures and non-resident issues.

Speakers: Paul Lynch, KPMG; Priceela Pursun, CRA

Priceela Pursun ; Paul Lynch

Session Change Break

Concurrent Sessions - choose from the following:

Technical Paper
Financial Services - Have you Arranged for Yourself to be At-Risk?

This session discusses the “financial service” definition under the Excise Tax Act. Much of the jurisprudence continues to centre on what constitutes a supply of “arranging for” a financial service and whether that supply is excluded from the definition by virtue of paragraphs (q), (r.2), (r.3), (r.4) or (t).

This paper discusses the recent jurisprudential developments in the application of the “financial service” definition, the interaction between the paragraphs, and the test developed by the Courts.

Speakers: Roxanne Wong, EY; David Robertson, EY Law LLP

David Robertson ; Roxanne Wong

Technical Paper
The Digital Economy – A Canadian Indirect Taxation Update

This paper will provide an update on the current state of indirect taxation in Canada of the digital economy and electronic commerce, with emphasis on non-resident suppliers of digital goods and services in Canada to businesses and consumers. The paper will consider application of the federal goods and services and harmonized sales taxes, Quebec sales tax (including the specified registration system for non-resident suppliers) and provincial sales taxes. Specific issues to be addressed include characterization of supplies, carrying on business in Canada, and the new GST/HST rules concerning cryptocurrencies. Finally, the paper will conclude with speculation as to both the efficacy of current taxation measures and anticipated future Canadian tax developments relating to the digital economy.

Speakers: Craig McDougall and Andrew Bateman, Felesky Flynn LLP

Craig McDougall ; Andrew Bateman

Coffee Break - Exhibits Open

An Update from the CRA

Speaker: Danielle Laflèche and Jennifer Ryan, CRA

Danielle Laflèche

Networking Lunch

GST Leaders Update

Concurrent Sessions - choose from the following:

Duty of Care Owed to Taxpayers

Speakers: Neil Bass and Angelo Gentile, Aird & Berlis LLP

Angelo Gentile ; Neil Bass

PST Hot Topics

Speaker: Andrew Azmudeh, Deloitte

Session Change Break

Concurrent Sessions - choose from the following:

Technical Paper
What's Fair and Reasonable? PSBs and Businesses Making Mixed Supplies

Speakers: Brittany Poon and Mitch LaBuick, BDO Canada LLP

Issues Faced in Real Property

Speaker: Christina Zurowski, Grant Thornton

Coffee Break - Exhibits Open

Provincial PST Panel

Moderated By: Amrita Abraham, Scotiabank
Panelists: David Taillon, Government of Manitoba; Michelle Lee, Government of British Columbia; Leslie Jerkovits, Government of Saskatchewan

Leslie Jerkovits

Conference Adjourns

This is the agenda for Post-Symposium
Post-Symposium October 25th, 2019
Post Symposium Workshop: Fundamental Legal Principles for the Commodity Tax Practitioner: A Practical Approach

Fundamental legal principles provide the foundation for the application of commodity tax. Mastering such principles assists the commodity tax practitioner not only in advising on transactions but also in the resolution of disputes with tax authorities and between contracting parties.

This workshop will offer a practical approach by applying targeted concepts of trust law, contract law and corporate law to situations encountered daily by practitioners. In addition, key legal concepts including consideration, delivery, indemnification and the legal differences between agreements, purchase orders and invoices will be explored.

Participants will leave this session not only with a toolbox of relevant legal principles but also with practical advice on how to apply such principles to their daily practice.

Speakers: Thomas Brook and Michael Citrome, EY Law LLP

This is the agenda for
2019 Advisory Committee
Thank you to our Advisory Committee

Sania Ilahi (Chair)
Ernst & Young LLP

Amrita Abraham

David Card

Barbara Hoffmann
B. Hoffmann Associates Ltd.

Alan Kenigsberg

Brent Murray

Shelley Smith
BDO Canada

Barbara Hoffman ; David Card ; Alan Kenigsberg ; Sania Ilahi ; Shelley Smith ; Brent Murray