Download PDF - Federated Press

Course Leader
Sean Kruger,
Ernst & Young
LLP
Inaugural
participating organizations
Chappell Partners LLP
Cirque du Soleil Inc.
The Claret Partners Limited
Davis LLP
Ernst & Young LLP
Fraser Milner Casgrain LLP
Goodmans LLP
Gowling Lafleur Henderson LLP
McGovern Hurley Cunningham LLP
Miller Thomson LLP
PricewaterhouseCoopers LLP
Shoppers Drug Mart Corporation
TD Bank Financial Group
Symcor Inc.
Frank E.P.
Bowman,
Fraser Milner
Casgrain LLP
who should attend
Tax VPs, Directors &
Managers; CFOs;
Treasurers; Tax
Accountants; Business
Valuators; Comptrollers;
Corporate Tax Counsel;
Estate Planners;
Financial Planners; Tax
Lawyers; Consultants
Peter Effer,
Shoppers Drug
Mart
Corporation
course highlights
Glenn Ernst,
Goodmans LLP
Christian
Fanning,
PricewaterhouseCoopers
LLP
Two-Day Event!
Abigail Kan,
McGovern
Hurley
Cunningham
LLP
Bulletproofing
Your Tax Practice
Michael
Morgan,
Chappell
Partners LLP
Course Leader
David W.
Chodikoff,
Miller Thomson
LLP
David
Nathanson,
QC, Davis LLP
Angelo
Bertolas,
TD Bank
Financial
Group
Ana Sainz,
The Claret
Partners Limited
Donald G.H.
Bowman,
Fraser Milner
Casgrain LLP
Linda Spencer,
Symcor Inc.
David Stevens,
Gowling Lafleur
Henderson LLP
Marie-Noel
Fredette,
Cirque du Soleil
Inc.
January 16 & 17, 2013, Toronto
Effectively dealing with business, legal and regulatory challenges to the tax practice
Workshop Included:
Handling Tax Audits and
Disputes to Avoid Tax
Litigation
• Strategic planning in successfully navigating new
constraints on tax avoidance
• Insight into the expanded reporting & disclosure re
quirements and how to maintain compliance for
aggressive tax planning disclosure
• The scope of tax risk management in an increasingly
complex business and regulatory environment
• Latest tax avoidance legislation & GAAR case law
developments
• The scope of the CRA’s powers to request the
production of documents and information
• Dealing with a tax mistake
• Integrating tax risks into an overall risk management
program
• Transfer pricing anti-avoidance issues
• Handling tax audits and disputes to avoid tax litigation

FACULTY
COURSE LEADERS
SEAN KRUGER
Sean Kruger is a Partner in Ernst & Young’s
Toronto Transfer Pricing practice. He has
undertaken transfer pricing projects in a
wide range of industries over a 10 year
period.
DAVID W. CHODIKOFF
David W. Chodikoff is a Partner with Miller
Thomson LLP. Hef specializes in Tax Litigation
(Civil and Criminal) and International
Tax Dispute Resolution.
CO-LECTURERS
ANGELO BERTOLAS
Angelo Bertolas is Vice President Canadian
Tax at TD Bank Group based in Toronto
were he is responsible for Canadian Tax
Compliance, Global Tax Governance and
Tax Authority Relations.
DONALD G.H. BOWMAN
As former Chief Justice of the Tax Court of
Canada, the Honourable Donald G.H. Bowman
has extensive experience in resolving
tax disputes. He is Counsel to FMC’s
National Tax Group.
COURSE PROGRAM
PANEL: BULLETPROOFING THE TAX PRACTICE - A TAX
EXECUTIVES’ PERSPECTIVE
This roundtable discussion featuring leading Canadian tax executives
will explore the key issues raised at this course, focussing on
the strategic planning involved in successfully navigating the new
constraints on tax avoidance while limiting the risks of tax planning
and compliance.
• Effectively managing tax risks
• Emerging tax compliance concerns
• Avoiding tax litigation
• Approaches for dealing with the CRA
SUPPLEMENTARY COURSE MATERIAL
FRANK E.P. BOWMAN
Frank E.P. Bowman is one of the most senior
partners in Fraser Milner Casgrain’s litigation
department. He has extensive experience in
representing and advising tax professionals on
professional liability issues.
PETER EFFER
Peter D. Effer is VP, Taxation with Shoppers
Drug Mart Inc.
GLENN ERNST
Glenn Ernst is a partner in the Tax Group at
Goodmans. He practices in all areas of taxation
including income taxation, commodity
taxation and taxation litigation.
CHRISTIAN FANNING
Christian Fanning is a partner in the Tax Services
group of PricewaterhouseCoopers LLP
working in the Montreal office.
MARIE-NOEL FREDETTE
Marie-Noel Fredette is Tax Director, Compliance
with Cirque du Soleil Inc.
ABIGAIL KAN
Abigail Kan is Senior Tax Manager at McGovern,
Hurley, Cunningham LLP.
MICHAEL MORGAN
Michael C. Morgan is a Partner of Chappell
Partners LLP in Toronto.
DAVID NATHANSON
Located in Toronto office of Davis LLP. David
C. Nathanson, Q.C., is one of the country’s
foremost tax litigators and specialists.
ANA SAINZ
Ana Sainz is the lead practitioner at The
Claret Partners Limited with over 25 years
experience across a variety of industries.
LINDA SPENCER
Linda Spencer is Senior Manager, Tax at
Symcor Inc.
DAVID STEVENS
David Stevens is a Partner at Gowling Lafleur
Henderson LLP, concentrating on personal
tax planning, business succession planning,
trusts and corporate tax.
NEW ENVIRONMENT FOR INFORMATION REPORTING AND
DISCLOSURE: AGGRESSIVE TAX PLANNING DISCLOSURE
The CRA has adopted an aggressive tax planning reporting regime that
requires the disclosure of certain tax avoidance transactions. This session
will look at the expanded reporting and disclosure requirements
and provide insight on how to maintain compliance for aggressive tax
planning disclosure.
• Leading practices in tax financial reporting: overcoming new
reporting challenges
• Impact of the 2011 OECD Report for tackling aggressive tax planning
• Mandatory disclosure obligations that target marketed tax
transactions
• Information reporting for aggressive transactions
• Disclosure of uncertain tax positions
Federated Press is now providing delegates with access to an innovative new database containing at least 25 interactive multimedia presentations by
leading experts and approximately 20 hours of lectures on the topics covered by this course, including all slides and speakers’ papers. See the list of
presentations on page 4.
Delegates will also receive a trial subscription to the Taxation Channel, a much broader resource representing hundreds of hours of interactive multimedia
lectures on leading edge Taxation topics as delivered at our many recent Taxation conferences and courses.

COURSE PROGRAM
PRACTICAL TAX RISK MINIMIZATION STRATEGIES
Tax departments face a greater risk of being noncompliant with tax
laws and regulations, and are more apt to enter into disputes with tax
authorities. This session will explore scope of tax risk management
amid an increasingly complex business and regulatory environment.
• Sources of internal tax risk
• Streamlining and improving processes and controls
• Designing and testing effective internal controls
• Tax risk management in practice: tax risk assessment & monitoring
• Establishing a tax control framework
LATEST TAX AVOIDANCE LEGISLATION & CASE LAW
Though the concept of GAAR is a critical component of the Income
Tax Act, its interpretation regarding how broadly the rule can be applied
is evolvin. This session will examine recent GAAR case law.
• Impact of the Copthorne Case on the scope of GAAR
• Using case law to determine certainty and predictability of tax
planning under GAAR
• Areas for future disputes: next battlegrounds on the horizon
• GAAR doctrine and impending case law: applying the GAAR
• Comparison of the CRA’s and Quebec’s aggressive tax planning
reporting regime
CRA REQUIREMENTS TO PRODUCE DOCUMENTS
The CRA has a variety of far-reaching powers to obtain information
that it requires to assess transactions. This session will look at the
scope of the CRA’s powers.
• Scope of CRA powers to obtain domestic-based and foreign-
based information
• Limits on the exercise of CRA powers
• Sanctions for failing to comply: exclusion in subsequent litigation
• Contesting requests for information
DEALING WITH TAX MISTAKES
Tax mistakes can take many forms. This session will examine alternatives
to be considered by tax professionals in dealing with a tax
mistake.
• Documenting past transactions and fixing mistakes
• Legal methods available to fix errors and mistakes
• Use of retroactive or retrospective documentation
• Capacity of parties to rescind or “undo” transactions
• Backdating in documenting transactions
INTERPROVINCIAL TAX PLANNING
This session will explore interprovincial tax planning in light of recent
government responses to various transactions that attempted to take
advantage of aggressive tax planning.
• Income tax arbitrage opportunities available
• Review of recent interprovincial tax transactions
• Addressing interprovincial tax planning
• Methods to take advantage of different elections
TAX RISK MANAGEMENT: INTEGRATION WITH ERM
This session will discuss tax risk management, and how it can be effectively
integrated into an overall risk management program.
• Incorporating tax risk management into overall ERM strategy
• Developing a formal enterprise tax risk management policy
• Fundamental elements of an effective tax risk management
process
• Impact that strong tax governance can have on relationships with
tax authorities and the cost of compliance
TAX COMPLIANCE FOR U.S. OPERATIONS
When involved in cross border business, one of the most important
issues to consider in order to stay compliant and reduce risk is the
accounting for uncertainty in income tax, as the IRS requires most corporate
taxpayers to file a Schedule Uncertain Tax Positions report.
• Meeting the measurement of uncertainties under ASC 740-10-50
(FIN 48) and IAS 37
• IAS 12 and ASC 740 overview
• Interim reporting issues
• Dealing with uncertain tax positions
• Anti-avoidance rules built into the Canada-U.S. Tax Treaty
ANTI-AVOIDANCE RULES FOR OWNER MANAGERS
This session will examine recent developments in Canada that have
had a direct impact on the taxation of owner-managed businesses.
• Section 84.1
• New prohibited investment rules for registered plans
• New rules for RCAs
• Associated corporations and the small business deduction
• Employee compensation issues: Transalta, the new EPSP rules
TRANSFER PRICING ANTI-AVOIDANCE
The growing interest of tax authorities in transfer pricing has resulted in
increased scrutiny of cross-border tax and customs issues. This session
will examine Canadian cross-border tax that impacts on multinationals.
• Recent Canadian transfer pricing developments
• Legal framework governing transfer pricing
• The 2012 Canadian Federal Budget issues
• Tax treaty developments
• Advance pricing arrangements as a means to limit risks
DEALING PROFESSIONAL NEGLIGENCE ISSUES
The scope of tax professionals’ liability is expanding. This session will
examine the main reasons for negligence actions against tax professionals.
• Circumstances in which professional liability claims ordinarily arise
• Best practices for limiting exposure to liability for negligence
• Dealing with negligence issues in the tax practice
• Defensive practices for tax practitioners in times of increased
scrutiny
• Liability and the use of insurance
WORKSHOP
HANDLING TAX AUDITS AND DISPUTES TO AVOID TAX
LITIGATION
Tax audits are a time-consuming and expensive proposition, and can
result in unexpected litigation. There is also no doubt that tax audits in
Canada are becoming more sophisticated. This workshop will review
the tax director’s role in managing a tax audit.
• Types of tax audits and audit preparation
• Managing the audit and managing conflict
• Using outside advisors
• Real-time audits
• Advance pricing agreements
• Settling a tax dispute before it gets to court
• Mediation, arbitration and settling tax cases based on risk
assessment

MULTIMEDIA
Your registration includes an interactive multimedia database comprising the following presentations from recent Federated Press courses and conferences.
They are presented in their entirety with complete audio or video and accompanying slides. You may also purchase the multimedia proceedings of the
course which will be available on CD-ROM 60 days after the course.
Managing Risks in a Tax Audits
David C. Nathanson, Q.C.
Davis LLP
Developing a Formal Tax Risk Strategy
Harold Chmara
Deloitte & Touche LLP
Tax Reporting as a Corporate Governance
Issue
Diana Bawn
John Hancock Financial Services Inc.
Dispute Resolution in Transfer Pricing:
Arbitration
Robert A. Davis, CA
KPMG LLP
Solving Non-Compliance Through Voluntary
Disclosure
Stevan Novoselac
Gowlings
Evaluating Internal Controls and Reporting
Practices
Diana Bawn
John Hancock Financial Services Inc.
Canadian Corporate Finance Structures &
Domestic Tax Planning
Brian D. Segal
Baker & McKenzie LLP
Transfer Pricing & Financial Transactions:
Dealing with Intangibles
Salvador M. Borraccia
Baker & McKenzie LLP
Developments in Tax Disclosure Requirements
Robert Kepes, B.C.L., LL.B.
Morris & Morris LLP
IRS Increased Tax Enforcement & Audits
Ian Bristol
Moskowitz & Meredith LLP
Transfer Pricing Audits & Dispute Resolution
John J. Tobin
Torys LLP
Managing Tax Audits: Key Issues
John Giakoumakis
Barrick Gold Corporation
Transfer Pricing Accounting and Reporting
Requirements
Jamal Hejazi
Gowling Lafleur Henderson LLP
Managing Transfer Pricing Audits
Andrew Kingissepp
Osler, Hoskin & Harcourt LLP
Dealing with CRA
Ralph T. Neville
BDO Dunwoody LLP
Tax Traps and How to Avoid Them
Jason Swales
PricewaterhouseCoopers LLP
Panel: The Latest Tax-Avoidance & GAAR
Developments
Mark Brender
Osler, Hoskin & Harcourt LLP
Registration: To reserve your place, call Federated Press toll-free at 1-800-363-0722.
In Toronto, call (416) 665-6868 or fax to (416) 665-7733. Then mail your payment along with the
registration form. Places are limited. Your reservation will be confirmed before the course.
Location: Courtyard by Marriott Downtown Toronto 475 Yonge Street, Toronto, ON M4Y 1X7
Conditions: Registration covers attendance for one person, the supplementary course material
as described in this document, lunch on both days, morning coffee on both days and
refreshments during all breaks. The proceedings of the course will be captured on audio or
video. Multimedia proceedings with all slides and handouts can be purchased separately on a
CD-ROM which will also include the course material.
Time: This course is a two-day event. Registration begins at 8:00 a.m. The morning sessions
start promptly at 9:00. The second day ends at 4:00 p.m.
TO REGISTER FOR BULLETPROOFING YOUR TAX PRACTICE
Name
Title Department
Approving Manager Name
Approving Manager Title
Organization
Address
City Province Postal Code
Telephone Fax e-mail
Please bill my credit card: AMEX VISA Mastercard
# Expiration date:
Signature :
Payment enclosed: Please invoice. PO Number:
WHEN CALLING, PLEASE MENTION PRIORITY CODE:
BPTP1301/E
MAIL COMPLETED FORM WITH PAYMENT TO:
Federated Press P.O. Box 4005, Station “A”
Toronto, Ontario M5W 2Z8
Managing Risks in a Tax Audit
Patrick L. Lindsay
Osler, Hoskin & Harcourt LLP
Claiming Privilege Against CRA: Protecting
Privileged Documents
Dan Misutka
Fraser Milner Casgrain LLP
Handling a CRA Audit of Your Foreign Affiliates
Tara Salmon
PricewaterhouseCoopers LLP
Insight into CRA Review Procedures/ Taxpayer
Challenges
Pesh Patel
Deloitte & Touche LLP
Transfer Pricing From a CFO’s Perspective
Martin Przysuski
BDO Dunwoody LLP
Managing a Tax Audit: The Tax Director’s Role
Pierre Bocti
Hewlett-Packard (Canada) Co.
US/Canadian Tax Reporting: Uncertain Tax
Positions
Paul Seraganian
Osler, Hoskin & Harcourt LLP
Tax Accounting and Reporting for Business
Combinations
Ray Kinoshita
Grant Thornton LLP
Cancellation: Please note that non-attendance at the course does not entitle the registrant
to a refund. In the event that a registrant becomes unable to attend following the deadline for
cancellation, a substitute attendee may be delegated. Please notify Federated Press of any
changes as soon as possible. Federated Press assumes no liability for changes in program content
or speakers. A full refund of the attendance fee will be provided upon cancellation in writing
received prior to January 2, 2013. No refunds will be issued after this date.
Discounts: Federated Press has special team discounts. Groups of 3 or more from the same
organization receive 15%. For larger groups please call.
Payment must be received prior to January 9, 2013
Phone: 1-800-363-0722 Toronto: (416) 665-6868 Fax: (416) 665-7733
/
REGISTRATION COSTS
NUMBER OF PARTICIPANTS:
COURSE: $1975
COURSE + PROCEEDINGS CD-ROM:
$1975 + $175 = $ 2150
PROCEEDINGS CD-ROM: $599
NOTE: Please add 13% HST to all prices.
Proceedings CD-ROM will be available 60 days
after the course takes place
Enclose your cheque payable to
Federated Press in the amount of:
GST Reg. # R101755163
PBN#101755163PG0001
For additional delegates please duplicate this form
and follow the normal registration process