in-depth tax course – part 3 · • reorganization issues ... including tax-efficient acquisition...
TRANSCRIPT
Announcing...
“Network with some of the brightest tax professionals from across Canada”
R an integral part of and logical follow-up to the In-Depth Tax Course – Parts 1 & 2, building on the concepts learned in corporate reorganizations and international tax
R a four-day, In-Depth program designed to help the full-time tax practitioner reach for the next level in tax training
R the ideal introduction and springboard to our Specialized In-Depth Tax Courses
August 16-20, 2014 n Whistler Conference Centre n Whistler, BC
An Essential Piece of Training for the Complete Tax Practitioner
FINAL OFFERING
In-Depth Tax Course – Part 3The 2014
REGISTRATION IS LIMITEDREGISTER EARLY!
STOCK OPTIONS• Computation of stock option benefits• Prescribed share requirements• Reorganization issues• Exercising or eliminating options
DEBT RESTRUCTURING AND DEBT FORGIVENESS• Debt parking rules• Debt forgiveness planning
TAX LOSS PLANNING• Tax Policy Considerations• Superficial, suspended and denied losses• Loss trading rules and subsection 69 (11)• Loss utilization
AMALGAMATION AND WIND UP TRANSACTIONS• Impact of amalgamations and wind-ups
on corporations and shareholders• 88 (1)(d) bump• Using the bump – timing issues
SECTION 55 • BUTTERFLY REORGANIZATIONS • 55(2) Application• Detailed review of divisive reorganization
rules in 55(3)(b) and 55 (3.1)
REORGANIZATION SPECIAL TOPICS• Earnouts• Contingent liabilities• Restrictive covenants• Taxable Canadian property• Transaction costs
Nik Diksic is a tax partner with Ernst & Young’s International Tax Services group. Nik’s practice is focused primarily on cross-border tax planning, including tax-efficient acquisition and financing structures. Nik has been a tutor at the In-Depth Tax Course and has presented at the Annual Conference of the Canadian Tax Foundation.
Rick McLean is a partner in the Mergers & Acquisitions Tax Services Group at KPMG LLP in Toronto and the leader of KPMG’s corporate reorganizations tax practice. Rick has extensive experience in structuring Canadian and international mergers, acquisitions, divestitures and corporate reorganizations. Rick has presented at the Canadian Tax Foundation’s Annual Conference and Ontario Tax Conferences and has been a tutor for the Corporate Reorganizations Tax Course and the In-Depth Tax Course.
August 16-20, 2014 n Whistler Conference Centre n Whistler, BC
In-Depth Tax Course – Part 3 In-Depth Tax Course – Part 3
August 16-20, 2014 n Whistler Conference Centre n Whistler, BC
FOREIGN AFFILIATES• Use of Foreign Branch• Overview of Foreign Affiliate System
o Branch versus subsidiary o Key definitions and ruleso Surplus pools and taxation of
dividends• FAPI
o Defining FAPI o Components of FAPIo Recharacterization ruleso Computing your share of FAPI
• Foreign Affiliate Special Rules and Issues
o Taxation of capital gainso Special surplus calculation ruleso Corporate consolidationo Surplus entitlement changeso Upstream loan proposalso Foreign Affiliate Dumping Rules
FINANCING STRUCTURES AND TREATY ISSUES • Cross-border financing structures and
tax issues to consider• Hybrid entities/instruments• Tax treaty considerations – Article IV
and LOB clause
A first-class faculty with leading-edge tax
Who should attend:R Professionals working full-time in tax, who have completed
the In-Depth Tax Course - Parts 1 and 2
R Other qualified individuals who are working full-time, primarily on income tax related matters, may also be eligible.
Four key benefits to attend Part 31. A Proven Instruction System – High quality lectures in a
traditional classroom setting and facilitated small group tutorials
2. An Expert Faculty – A technical lecture and tutor group team providing a wealth of knowledge and experience
3. An Unparalleled Learning Environment – A unique occasion for continued growth to increase your ability to offer your clients the highest level of expertise
4. An Unmatched Opportunity – To network with some of the brightest tax professionals from across Canada
2014 Part 3 Program Outline
2014
CANCELLATION POLICY: If you are unable to attend the course for any reason, you may substitute, by arrangement with the Participant Coordinator, someone who meets the qualifications from your organization , or, you may cancel. Course cancellations will be subject to a $300 administration fee (plus applicable taxes). Cancellations within 30 days are subject to the $300 administration fee (plus applicable taxes) and any related hotel cancellation fees. PLEASE NOTE: All cancellations must be received in writing by e-mail to [email protected].
STOCK OPTIONS• Computation of stock option benefits• Prescribed share requirements• Reorganization issues• Exercising or eliminating options
DEBT RESTRUCTURING AND DEBT FORGIVENESS• Debt parking rules• Debt forgiveness planning
TAX LOSS PLANNING• Tax Policy Considerations• Superficial, suspended and denied losses• Loss trading rules and subsection 69 (11)• Loss utilization
AMALGAMATION AND WIND UP TRANSACTIONS• Impact of amalgamations and wind-ups
on corporations and shareholders• 88 (1)(d) bump• Using the bump – timing issues
SECTION 55 • BUTTERFLY REORGANIZATIONS • 55(2) Application• Detailed review of divisive reorganization
rules in 55(3)(b) and 55 (3.1)
REORGANIZATION SPECIAL TOPICS• Earnouts• Contingent liabilities• Restrictive covenants• Taxable Canadian property• Transaction costs
Nik Diksic is a tax partner with Ernst & Young’s International Tax Services group. Nik’s practice is focused primarily on cross-border tax planning, including tax-efficient acquisition and financing structures. Nik has been a tutor at the In-Depth Tax Course and has presented at the Annual Conference of the Canadian Tax Foundation.
Rick McLean is a partner in the Mergers & Acquisitions Tax Services Group at KPMG LLP in Toronto and the leader of KPMG’s corporate reorganizations tax practice. Rick has extensive experience in structuring Canadian and international mergers, acquisitions, divestitures and corporate reorganizations. Rick has presented at the Canadian Tax Foundation’s Annual Conference and Ontario Tax Conferences and has been a tutor for the Corporate Reorganizations Tax Course and the In-Depth Tax Course.
August 16-20, 2014 n Whistler Conference Centre n Whistler, BC
In-Depth Tax Course – Part 3 In-Depth Tax Course – Part 3
August 16-20, 2014 n Whistler Conference Centre n Whistler, BC
FOREIGN AFFILIATES• Use of Foreign Branch• Overview of Foreign Affiliate System
o Branch versus subsidiary o Key definitions and ruleso Surplus pools and taxation of
dividends• FAPI
o Defining FAPI o Components of FAPIo Recharacterization ruleso Computing your share of FAPI
• Foreign Affiliate Special Rules and Issues
o Taxation of capital gainso Special surplus calculation ruleso Corporate consolidationo Surplus entitlement changeso Upstream loan proposalso Foreign Affiliate Dumping Rules
FINANCING STRUCTURES AND TREATY ISSUES • Cross-border financing structures and
tax issues to consider• Hybrid entities/instruments• Tax treaty considerations – Article IV
and LOB clause
A first-class faculty with leading-edge tax
Who should attend:R Professionals working full-time in tax, who have completed
the In-Depth Tax Course - Parts 1 and 2
R Other qualified individuals who are working full-time, primarily on income tax related matters, may also be eligible.
Four key benefits to attend Part 31. A Proven Instruction System – High quality lectures in a
traditional classroom setting and facilitated small group tutorials
2. An Expert Faculty – A technical lecture and tutor group team providing a wealth of knowledge and experience
3. An Unparalleled Learning Environment – A unique occasion for continued growth to increase your ability to offer your clients the highest level of expertise
4. An Unmatched Opportunity – To network with some of the brightest tax professionals from across Canada
2014 Part 3 Program Outline
2014
CANCELLATION POLICY: If you are unable to attend the course for any reason, you may substitute, by arrangement with the Participant Coordinator, someone who meets the qualifications from your organization , or, you may cancel. Course cancellations will be subject to a $300 administration fee (plus applicable taxes). Cancellations within 30 days are subject to the $300 administration fee (plus applicable taxes) and any related hotel cancellation fees. PLEASE NOTE: All cancellations must be received in writing by e-mail to [email protected].