Course Outline

Below is the course outline for MGTL Uni on Tuesday, June 12, 2018. Please review the courses, and identify which ones you would like to attend prior to arriving. If at any point during the day you would like to switch classes, you are free to move back and forth as you wish.

 

8:30 – 8:35 AM Introduction
8:35 – 9:20 AM Canadian Private Corporation Tax Proposals  – July 18, 2017 to Present – Where Have We Been and Where Do We Go From Here?

This session will provide a historical review of the events from July 18, 2017 concluding with the 2018 Federal Budget and provide overall comments on the resulting impacts to private clients.

9:25 – 10:50 AM The “Income Sprinkling” Amendments – Tax on Split Income (“TOSI”)

This session will take a deep dive into the new rules and its impact on owner-manager remuneration (including a quick review of the use of retirement compensation arrangements and individual pension plans)

10:50 – 11:05 AM Break
11:05 – 12:05 PM The Top 10 US Tax Reform Issues for Canadians

This session will review the top 10 issues that will affect Canadians as a result of US Tax Reform. You don’t think US tax reform affects you or your clients? Then buckle up….you’re in for a surprise.

12:15 – 1:15 PM Lunch – Keynote – Tom Deans PhD (Author of the All Time Best Selling Family Business Book – “Every Family’s Business”)

In his talk, Tom will offer a compelling argument why families should be clear about when they will sell the business and to whom. Families that are upfront and realistic about their goals for transitioning ownership of the business can avoid jealousy, sibling rivalry and regrettable inter-family lawsuits. In this keynote talk, Tom will provide advisors the common misconceptions about gifting a family business, discuss the 12 Common Sense Questions for getting a succession plan started, learn about strategies to help families to find their own succession solution and discuss the secrets of protecting wealth that the world’s dynastic families have known for centuries.

Concurrent Sessions

Canadian Tax Advisory Stream Canada / US Cross-Border Stream
1:35 – 2:30 PM Canadian Departure Tax Considerations

Personal tax increases, US tax reform and overall anti-business policies have caused many Canadians to leave Canada or consider leaving. This session will review in detail the Canadian tax considerations that must be considered when an individual becomes a non-resident of Canada.

1:35 – 2:30 PM US Renunciation / Immigration Considerations

In Canada, there are over 1 million US citizens that are residents of Canada. You have clients that are US citizens.  Such persons face increased compliance and tax needs and often their financial planning is fraught with complexity. Many of these people have or are considering renouncing their US citizenship. This session will provide the basics of US tax and immigration considerations that such persons and their advisors will need to consider when planning to renounce their US citizenship.

2:35 – 3:30 PM Passive Investment Proposals

Part of the July 18, 2017 private corporation tax amendments included controversial proposals to dramatically change the taxation of investment income earned by a Canadian-controlled private corporation. The 2018 federal budget included the final revised proposals that was a dramatic climb-down from the original material. This session will review the final proposals and provide practitioners with considerations / planning tips to deal with the new amendments.

2:35 – 3:30 PM Outbound US Planning and Immigration

US tax reform has dramatically changed – almost overnight – how Canadian businesses invest in the US  This session will review the basic considerations and provide examples of how Canadians might invest in the US.

3:30 – 3:45 PM Break 3:30 – 3:45 PM Break
3:45 – 4:45 PM Subsection 55(2) and Safe Income Considerations

In April 2015, the Department of Finance released proposals to subsection 55(2) that have since been finalized into law with minor amendments.  Such changes dramatically impacts the landscape with respect to inter-corporate cash movements.  This session will quickly review the legislative changes and provide practitioners with practical take-aways with respect to how to deal with the new landscape.

3:45 – 4:45 PM US Transition Tax, GILTI and FDII

Expanding upon The Top 10 US Tax Reform Issues For Canadians session, this session will take a deeper dive into some of the nasty “surprises” that US tax reform has left certain Canadians to deal with.  This session will quickly review the US transition tax, the “GILTI” and “FDII” that practitioners will need to be aware of when dealing with their clients who are US citizens who hold certain interests in Canadian corporations.

Plenary
4:45 – 5:30 PM The Future of the Private Client Practitioner and Practical Tools to Deal with Change

This final session will provide a holistic view of the overall landscape for advisors to private clients with a particular emphasis on the tax function.  What changes can we expect in 5 years?  In 10 years?  How will such changes change your practice?  What can or should you do to keep pace proactively?

5:30 – 6:30 PM Networking
Confirmed Speakers: Kim G C Moody, Kenneth Keung, Marsha-laine Dungog, Azam Rajan, Oliver Branch, Alexander Marino with others to be added later.