A two-day technical tax update with live group instruction featuring plenary and workshop sessions on current U.S. and Canadian tax issues affecting structuring, acquiring, financing, operating or disposing of a Canadian or U.S. affiliate today. 

 

Course Level: Update Delivery Method: Live Group

LEARNING OBJECTIVES 

After attending this event, participants will be able to:
• Describe internal restructuring techniques: Sec 304 and recent trends
• List withholding tax requirements for U.S. persons for withholdable payments under Sec. 1471
• Discuss Canada tax legislation and CRA pronouncements affecting Canadian and U.S. multinationals
• Evaluate current issues in reconciling the statutory and effective tax rate for IFRS/GAAP financial reporting purposes
• Identify special state tax issues, including sales and use tax, royalty income and intangible licensing issues
• Understanding the rules in Canada for tax-free reorganizations, including amalgamations, spin-offs and split-ups

 

 Registrants at our two-day 19th Annual Tax Update also attend Bloomberg BNA’s one-day 12th Annual Canada-U.S. Transfer Pricing Symposium for FREE! 

PREREQUISITES

There are no prerequisites for attending this program.

All paid attendees will receive the Bloomberg BNA Portfolio: #7050, Business Operations in Canada
*One Portfolio per paid attendee. Quantities are limited.

SUBSTITUTIONS, CANCELLATIONS & COMPLAINTS

If you are unable to attend this event, you may: transfer your registration to another person from your company for the same event; or transfer your registration to a substitute event listed on our web site. In either instance, there will be no charge or penalty for substitution.

To request a transfer, contact customercare@bna.com with the new attendee or substitute event information more than 5 business days prior to the conference start date. On the first day of the event, absent attendees will be considered “no shows” and will not be eligible for a refund, transfer, or substitute event. Cancellations must be made in writing to customercare@bna.com more than 5 business days before the event and will be assessed a $350 conference setup fee. Cancellations will not be accepted if notice is received fewer than 5 business days before the event.

For more information regarding administrative policies, such as complaints and cancellations, please contact us at 800.372.1033, or e-mail customercare@bna.com.

Conference Sponsor

The Westin Harbour Castle
1 Harbour Square
Toronto, ON M5J 1A6
Canada
Tel: +1 416-869-1600

Limited Time Reduced Rates:
Single/Double $259.00
Triple $289.00
Quad $319.00

Our block of discounted sleeping rooms is limited, so please reserve your sleeping room early! We cannot guarantee rates or availability. Please contact the hotel and mention that you are attending the course listed under Bloomberg BNA. This limited-time discounted rate will be available up to 30 days prior to the meeting, or until the group block is sold-out, whichever comes first. Please note: your sleeping room is not included in the registration fee.

MONDAY, OCTOBER 21ST

8:00 am Registration and Continental Breakfast Begin

8:30 am Welcome – Chairpersons’ Overview

9:00 am Plenary Session # 1 – How Recent Tax Developments Affect Cross-Border U.S. and Canadian Operations
• A survey of the latest U.S. tax legislation, court cases, and IRS rulings and pronouncements
• Canada tax legislation and CRA pronouncements affecting Canadian and U.S. multinationals

10:30 am Break for Refreshments

10:45 am Plenary Session # 2 – How FATCA Affects U.S. and Canadian Non-Financial Institutions
• Understanding the FATCA regulations – defining Foreign
Financial Institutions (FFIs) and non-FFIs
• Understanding the new FFI registration Form 8957
• Withholding tax requirements for U.S. persons for withholdable payments under Sec. 1471

12:15 pm LUNCHEON

1:30 pm WORKSHOP 1 (Canadian Tax Practitioners)
Acquiring and Restructuring U.S. Operations
• Stock v. asset acquisitions - latest Sec. 338 election strategies
for stepping-up the basis of acquired assets
• Taxable v. tax-free acquisitions strategies - understanding the
U.S. rules for corporate acquisitions
• Internal restructuring techniques: Sec 304 and recent trends
• Understanding the foreign investment in real property tax act (“FIRPTA”)

WORKSHOP 2 (U.S. Tax Practitioners)
Acquiring and Reorganizing Canadian Operations
• Acquisitive transactions from the buyers'/sellers' perspective – taxable v. tax-free transactions
• Elections and tax reporting requirements for acquisitions in Canada – post-acquisition planning
• Understanding the rules in Canada for tax-free reorganizations, including amalgamations, spin-offs and split-ups
• Winding-up a Canadian corporation or partnership

2:30 pm Refreshment Break

2:45 pm WORKSHOP 3 (Canadian Tax Practitioners)
Minimizing State Income and Sales Taxes
• Understanding state tax nexus and jurisdiction issues – when is a company required to file a tax return?
• Separate vs. combined or unitary reporting - use of holding companies and other tax efficient structures for reducing state taxes
• State tax issues in tax-free acquisitions and reorganizations
• Special state tax issues, including sales and use tax, royalty
income and intangible licensing issues

WORKSHOP 4 (U.S. Tax Practitioners)
Update on GST/HST, De-Harmonization in BC and other Canadian Sales Taxes
• Review of harmonization status and ongoing issues, including key concepts
• Review of other GST and Canadian sales tax current topics

4:00 pm Plenary Session # 3 – Update on Accounting for Income Taxes for Canada-U.S. Operations
• Current issues in reconciling the statutory and effective tax rate for IFRS/GAAP financial reporting purposes
• Tax accounting rules on mergers and acquisitions - understanding the rules for goodwill under FAS #141/142
• Understanding how FIN 48 affects tax provision planning
• Update on effective tax rates in Canada and the United States in computing income tax provisions in 2012 and 2013

5:30 pm Meeting Adjourns for the Day

TUESDAY, OCTOBER 22ND

8:00 am Continental Breakfast

8:45 am Plenary Session # 4 - U.S. and Canadian Taxation of Executives Performing Cross-Border Services
• Latest individual tax issues in Canada and the United States
• How Canada - U.S. Income Tax Treaty affects taxation of non-resident individuals
• U.S. and Canadian non-resident taxation of real estate used by executives
• Reporting for Canadian or third country assets of U.S. persons

10:15 am Refreshment Break

10:30 am Plenary Session # 5 - Current Strategies for Financing U.S. and Canadian Operations
• Objectives of cross-border financing – treatment of guarantee fees
• Avoiding thin capitalization/earnings stripping issues on cross-border lending activities – maximizing interest expense benefits.
• Latest cross-border financing strategies for reducing U.S. and Canadian withholding taxes and related compliance issues.

12:15 pm LUNCHEON

1:30 pm Plenary Session # 6 - Structuring Cross-Border Real Estate Investments
• Identifying the proper vehicle and structure to satisfy investors’ goals
• Determining the U.S. and Canadian tax costs – measuring after-tax return on investment
• Use of widely-held partnerships and Canadian REIT Structures
• Practical withholding tax issues, including FIRPTA and section 116 certificates – interrelationship with Tax Treaty provisions

2:45 pm Refreshment Break

3:00 pm Plenary Session # 7 - Repatriating Earnings from Canadian and U.S. Affiliates and Cross Border Tax Minimization Strategies
• Understanding the surplus capital rules in Canada
• Tax issues involving cross-border royalty and technology transfers – interrelationship with the latest IRS service rules
• Understanding the affects of the latest U.S. international tax rules
• Dividends paid directly by U.S. or Canadian subsidiaries and through intermediate companies
• Understanding how the US Subpart F and Canadian FAPI rules apply

5:00 pm Meeting Adjourns



Times/Topics Subject to Change

Copyright Bloomberg BNA 2013

EDUCATIONAL COURSE CREDIT

 

UP TO 16 CPE CREDIT HOURS AVAILABLE

Bloomberg BNA is registered with the National Association of the State Boards of Accountancy as a sponsor of continuing professional education on the National Registry of CPE sponsors. State Boards of Accountancy have final authority on the acceptance of individual courses. Complaints regarding registered sponsors may be addressed to NASBA, 150 Fourth Avenue North, Suite 700, Nashville, TN 37219-2417.

UP TO 16 CPE CREDIT HOURS AVAILABLE 

Bloomberg BNA will apply for continuing legal education credits in any state or jurisdiction where available. For more information, please contact Bloomberg BNA customer service at 800.372.1033 and ask to speak to the CLE Accreditations Coordinator, or email us at accreditations@bna.com .

HARDSHIP POLICY

Bloomberg BNA offers a hardship policy for CPAs and other tax and accounting professionals who wish to attend our live conference and seminars. Individuals must earn less than $50,000 annually in order to qualify. For individuals who are unemployed or earning less than $35,000 per year, a full discount off the price of registration for the program will be awarded. Individuals earning between $35,000 and $50,000 per year will receive a 50% discount off the price of the program.

If an individual wishes to submit a case for hardship, he or she must contact Bloomberg BNA directly at accreditations@bna.com. Please include the following information with your request: complete contact information, program for which a hardship reduction is being requested, requested amount for hardship reduction, and reason for applying for hardship. Please note that requests will not be considered until 30 days from the program date and that individuals may only apply for a hardship reduction once within a 12-month period. Bloomberg BNA reserves the right to make a final determination on a case-by-case basis. Our decision for granting a hardship is final and submission does not constitute acceptance.