Tax Traps and Preventive Planning Seminar
$148 – $594
Tax Traps and Preventive Planning Seminar

Tax Traps and Preventive Planning Seminar

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Riviera Parque Dining, Banquet & Convention Centre

2800 Highway 7

Vaughan, ON L4K 1W8


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Take part in this exciting opportunity to discuss attribution, 55(2) Intercorporate Dividends, Section 84.1, and Shareholder Benefits via Seminar or Webinar. Our presenters come from MKW LLP, WeirFoulds LLP, SLF, and TaxationLawyers. 

The Breakdown of the Day is as Follows: 

8:40 - 9:00: Registration and Networking

First Session 9:00 - 10:30 - Attribution (Jennifer Leve)

  • An overview of attribution as a generally anti-avoidance provision. 
  • Impact on income tax splitting arrangements
  • Transfers of money or property to a spouse or minor
  • Trusts and what happens if the property reverts to the settlor contributor  
  • The lending of property can also trigger attribution rules.  

10:30 - 11:00: Networking and Coffee

Second Session 11:00 - 12:30 - 55(2) - Anti-surplus stripping / Intercorporate Dividends (Ryan Morris)

  • What is the impact on previously standard strategies such as:
    • Certain creditor proofing techniques and 
    • QSBC purification procedures.  
  • What are the implications to stock dividends and 
  • What are the changes to the calculation of safe income.

12:30 - 1:30: Networking and Lunch

Third Session 1:30 - 3:00 - Section 84.1 (Brett Starkman)

  • Section 84.1 is a specific anti-surplus stripping rule that has been in place since 1974! 
  • How does 84.1 stop the distribution of corporate surplus as an exempt capital gain.
  • What is PUC and how does 84.1 affect this. 
  • What are some examples of transfers that trigger 84.1
  • Why does it continue to pose problems to practitioners.

3:00 - 3:30: Networking and Coffee

Fourth Session 3:30 - 5:00 - Shareholder Benefits (James Rhodes)

    • Has the individual received a benefit as a result of being a shareholder or in his/her capacity as an employee. 
    • For Section 15(1) to apply, there’s generally three requirements. 
    • What is the impact on previously standard strategies such as:
    1. First the shareholder must actually get some benefit. 
    2. Second must intend to give the shareholder a benefit and 
    3. Third, if there is a benefit, an amount must be ascribed to it. 
    • What happens if  the shareholder has borrowed funds from the corporation and has not repaid the debt within one year after the end of the taxation year.

        Presenter Bio:

        • Jennifer Leve

          Jennifer Leve

          Morris, Kepes, Winters LLP


        Jennifer Leve is an associate at Morris, Kepes, Winters LLP and her practice focuses primarily on personal and corporate tax planning, corporate reorganizations and estate planning matters. She also represents clients in their dealings with the CRA.
        Jennifer received her LL.B. from Osgoode Hall Law School in 2005, and her Masters of Tax from the University of Waterloo in 2009. She has been a member of the Ontario Bar since 2007.
        Prior to joining MKW in 2015, Jennifer worked as a tax associate at a major international law firm where she provided a full range of domestic and cross-boarder tax advisory services to large corporate clients as well as charities and non-profit organizations. Jennifer also worked in-house in the tax department of a multinational insurance company, and in tax policy for a major Canadian industry association.

        • Ryan Morris

          Ryan Morris

          WeirFoulds LLP


        Ryan Morris  is Co-Chair of the Tax Group at WeirFoulds LLP. He regularly advises clients on various areas of domestic and international taxation, including advising on mergers and acquisitions, financings, withholding tax, employment issues and a broad range of corporate tax matters. Ryan also represents clients with audits, voluntary disclosures and appeals and has represented clients as lead counsel at every level of court, including Canada’s highest court, the Supreme Court of Canada. Ryan is the Tax Editor of Ontario Corporate Law & Practice and is also the co-editor and a frequent contributor to the Current Cases feature of the Canadian Tax Journal, the flagship research publication of the Canadian Tax Foundation.

        • Brett Starkman

          Brett Starkman


          Tax Partner

        Brett Starkman is a tax partner with SLF. With more than 20 years of experience he specializes in corporate restructuring and estate planning, international tax planning and structuring and in mergers and acquisitions.  Brett is the sole Canadian member on the HLB International Tax Committee.  He is quoted regularly in local newspapers, has been a speaker at numerous conferences and has appeared on radio and TV.

        Brett joined SLF in 1994 after spending eight years with an international accounting firm.

        • James Rhodes

          James Rhodes


          Tax Lawyer

        James Rhodes started his career as a tax lawyer first with the Tax Court of Canada (‘TCC’). He then worked at KPMG, and then Department of Justice where he was counsel on over one hundred appeals. Following this he has worked at Miller Thomson LLP, and now operates as TaxationLawyers. James handles all tax dispute resolution and tax litigation matters from dealing with the Canada Revenue Agency on audits and objections, appearing before the TCC and Federal Court of Appeal, to tax evasion charges. He also does Voluntary Disclosure Program applications, taxpayer relief requests, and rectification applications.
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        Date and Time

        Riviera Parque Dining, Banquet & Convention Centre

        2800 Highway 7

        Vaughan, ON L4K 1W8


        View Map

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