7:30-8:30
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8:30-9:30
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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.
Moderated by: Sania Ilahi, EY Speakers: Paul Lynch, KPMG; Priceela Pursun, CRA
Priceela Pursun
;
Paul Lynch
;
Sania Ilahi
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9:30-9:40
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9:40-10:40
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Concurrent Sessions - choose from the following:
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Technical Paper
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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
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Technical Paper
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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
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10:40-11:00
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Coffee Break - Exhibits Open
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11:00-12:00
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An Update from the CRA
Updates on audit programs, projects, and initiatives within GST/HST that would be of interest to professionals who are representing clients on GST/HST audits
Speaker: Danielle Laflèche and Tammy Meyers, CRA
Danielle Laflèche
;
Tammy Myers
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12:00-1:05
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1:05-2:05
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Concurrent Sessions - choose from the following:
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Duty of Care Owed to Taxpayers
What to do when the CRA behaves “badly”? As tax lawyers who deal extensively with all facets of the tax dispute process, a complaint that taxpayers occasionally raise with us is the conduct of the CRA in the course of audits, appeals, investigations and collection matters. Whenever a taxpayer feels aggrieved by such conduct, one of the first questions they ask is “can I sue the CRA for this?” This presentation will explore the current state of the law on the CRA’s duty of care to taxpayers, and the bases upon which a taxpayer might be able to sue the CRA civilly for damages. This session spotlights the practical challenges of successfully bringing a civil action against the CRA. The session then focuses on the myriad of non-civil action remedies which a taxpayer may try to avail itself of to resolve instances of alleged CRA misconduct.
Speakers: Neil Bass and Angelo Gentile, Aird & Berlis LLP
Angelo Gentile
;
Neil Bass
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PST Hot Topics
The provinces of British Columbia, Saskatchewan and Manitoba (the “PST Provinces) still have their own provincial retail sales taxes. Many businesses that are non-residents of the PST Provinces may not be familiar with the PST compliance requirements in these provinces. These businesses may operate in the PST Provinces without taking into consideration the application of the PST to their operations, including various administrative positions that are taken by the tax authorities. This session will cover certain issues that are generally raised by the tax authorities during an audit or issues that businesses raise with respect to the PST. This session will cover the following topics: (1) the application of PST to software in British Columbia, (2) the application of PST to real property contracts in British Columbia, (3) self-assessment of PST for goods and services acquired outside the PST Provinces and consumed in the provinces, (4) security and bonding in Saskatchewan and Manitoba, (5) real property and tangible personal property in Manitoba, (6) real property services in Saskatchewan, and (7) non-resident registration requirements in Saskatchewan.
Speaker: Andrew Azmudeh, Deloitte
Andrew Azmudeh
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2:05-2:15
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2:15-3:15
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Concurrent Sessions - choose from the following:
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Technical Paper
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What's Fair and Reasonable? PSBs and Businesses Making Mixed Supplies
Speakers: Brittany Poon and Mitch LaBuick, BDO Canada LLP
Brittany Poon
;
Mitch LaBuick
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Issues Faced in Real Property
Understanding how GST/HST applies to real property transactions can be challenging at best. Undoubtedly, the GST/HST provisions related to real property are somewhat complex and at times not necessarily intuitive. And, in many instances the potential dollars at stake may be significant. The following session provides an overview of how the provisions work, highlighting the specific areas and situations that may potentially create real challenges for organizations from a legislative but also practical perspective.
Speaker: Christina Zurowski, Grant Thornton
Christina Zurowski, CPA, CA
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3:15-3:30
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Coffee Break - Exhibits Open
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3:30-4:30
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Provincial PST Panel
The panel will provide a brief update on any legislative changes made in the last few years with respect to the provincial sales tax in British Columbia, Saskatchewan and Manitoba. Further, the panel will also provide a provincial perspective on the PST hot issues such as software, interprovincial services, non-resident registration requirements.
Moderated By: Amrita Abraham, Scotiabank Panelists: David Taillon, Government of Manitoba; Michelle Lee, Government of British Columbia; Leslie Jerkovits, Government of Saskatchewan
Leslie Jerkovits
;
Michelle Lee
;
David Taillon
;
Amrita Abraham
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4:30
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