Prairie Provinces Regional Tax Conference

Overview

This Canadian Tax Foundation program provided participants with a review of recent legislative and administrative developments in federal and provincial tax law, aimed specifically at central Canada.

Objectives

The objective of this conference was to enable participants, which included judicial and non-judicial participants, to assess practical ways of working around and through tax challenges and pitfalls, including best practices for resolving tax issues.

Summary

Higher instances of barter have created special challenges in tax law. Speakers addressed issues relating to international transactions including: residency; permanent establishment; carrying on businesses; Canada’s tax treaties; active and passive income earned by non-residents; disposition of taxable Canadian property; Regulation 102 and 105 withholdings; branch tax; and foreign tax credits and deductions. The sessions covered recent court decisions, including reviews of recent cases which affect owner-managed businesses and private companies. Cases reviewed included the recent Supreme Court of Canada (SCC) decisions in the Fairmont and Jean Coutu cases.

Speakers included representatives from private law firms, the Canada Revenue Agency, the Department of Justice and a judge from the Tax Court of Canada.