Canada is a jurisdiction multinational companies cannot afford to ignore. The Canada Revenue Agency is known for its aggressive stance in transfer pricing audits, and an ever-increasing number of these disputes are winding up in court. The Bloomberg BNA-Baker & McKenzie Canada Transfer Pricing Conference, to be held September 29 and 30 in Toronto, is specifically designed for those navigating this difficult landscape, with sessions on:• The Canadian audits and appeals process. This session will explore recent domestic changes, such as the CRA’s risk-based assessment approach, as well as describe recent audit experience.• Advance pricing agreements and competent authority. The CRA has become quite selective in the types of APA requests it will accept. This session will examine these restrictions and help companies weigh the value of an APA. It also will explore the state of negotiations between the U.S. and Canadian competent authorities and the impact of arbitration on both APAs and double tax cases.• Diverging economic views across borders. There are two sides to every transaction and two sets of government economists evaluating how to apply the arm’s-length principle to the transaction. In this session, Canadian and U.S. economists from the government and the private sector will discuss their views of stock options and stock-based compensation as an element of service charges, the role and applicability of comparable uncontrolled transactions, the treatment of intangibles, business restructuring and other issues.• Financial transactions. With little in the way of guidance on these transactions, the litigation involving GE Capital Canada remains the latest word on how to treat related-party guarantee fees. In this session, attendees will hear about key issues to consider when planning and pricing these transactions and gain insights from experts including the attorney who represented GE in the case.
Educational Course Credit: Up to 12 CPE/CLE Available
Click here to see an agenda and learn more about the Canada Transfer Pricing Conference.
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350 King St W Toronto, ON M5V 3X5Tel: 416-599-8433Hotel accommodations for the conference are available at:Hotel Le Germain 30 Mercer St Toronto, ON M5V 1H3, Canada Tel:+1 416-345-9500Limited time and number of reduced rate rooms: $269.00 per night. Please contact the Hotel Le Germain Maple Leaf directly for reservations.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 Bloomberg BNA conference.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.
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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 email@example.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.
Continental breakfasts, lunches, refreshment breaks, networking reception, and course materials in electronic format.