Cross-border Tax Update: A two day technical update with live group instruction featuring plenary and workshop sessions on current U.S. and Canadian tax issues in structuring,acquiring, financing, operating or disposing of an affiliate in Canada or U.S.

Transfer Pricing Symposium: A one-day advanced level session with live group instruction on Canada and U.S. cross-border transfer pricing developments affecting multinationals today

Cross-border Tax Update Highlights

• How recent tax developments affect cross-border U.S. and Canadian operations
• Structuring tax efficient cross-border manufacturing and distribution operations
• Special break-out sessions (7) on practical tax topics for Canadian and U.S. tax practitioners
• U.S. and Canadian taxation of executives performing cross-border services
• Find out the latest strategies for financing U.S. and Canadian operations
• Learn the latest developments under the Canada-US Income Tax Treaty
• Discover the latest techniques in repatriating earnings from Canadian and U.S. affiliates and cross-border tax minimization strategies
• Network with cross-border tax practitioners and let our experienced faculty assist you in planning for your cross-border operations in 2011

Transfer Pricing Symposium Highlights

• Discover the latest global and cross-border experiences in transfer pricing planning, including financial statement preparation
• Find out the latest audit issues being raised by the CRA and the IRS on cross-border sales, including the treatment of distributors
• Learn whether you should be charging your U.S. or Canadian affiliate for management or other services and the reaction of the tax authorities
• Determine if your company can benefit from a cost-sharing or cost contribution arrangement for funding intangible developments
• Network with corporate tax executives from Canadian and U.S. multinationals, as well as our faculty of experienced tax practitioners, including attorneys, solicitors, CPAs, CAs and economists, involved in the current Canada-U.S. transfer pricing planning and controversies

Educational Course Credit — Up to 7.5 CPE / CLE Credits Available

Substitutions/Cancellations

Cancellations received more than 72 business hours prior to the meeting will be issued a credit. A $350 fee will apply to cancellations received within 72 business hours of the event. No credit card or cash refunds will be issued at any time. For more information regarding administrative policies, such as complaints and refunds, please contact us at 1-914-328-5656, or e-mail info@citeusa.org. Credits will not be issued for "no shows"

A limited block of rooms at a reduced rate has been set aside for attendees of our conferences. Please contact the hotel and mention that you are attending the conference listed under the Council for International Tax Education (CITE) in order to receive the discounted rate. Sleeping rooms are available on a very limited basis. We cannot guarantee rates or availability. Your sleeping room is not included in your registration fee.

Canada - U.S. Cross-Border Tax Update

Monday, October 18th

7:30 am Registration and Continental Breakfast Begin

8:30 am CITE Welcome – Chairpersons’ Overview

9:00 am Plenary Session – How Recent Tax Developments Affect Cross-Border U.S. and Canadian Operations

• Update on latest U.S. tax legislation, court cases, and IRS rulings and pronouncements
• Canada tax legislation and CRA pronouncements affecting Canadian and U.S. multinationals
• Update on using hybrid entities in structuring Canada-U.S. operations
• 2010 tax planning under the latest U.S. - Canada Tax Treaty Protocol
  

10:30 am Break for Refreshments

10:45 am Plenary Session – Structuring Tax Efficient Cross Border Product Distribution

• Distribution Agent – Direct Sale vs. Independent Agent vs. Dependent Agent, Branch vs. Subsidiary
• Manufacturing Parent’s – Permanent Establishment exposure
• Profit Drivers for distributor’s taxable income, e.g., inventory ownership, credit risk, marketing intangibles
• Full Distributor or Stripped Distributor – potential tax issues on converting to stripped distributor
• Adjusting contracts in a down economy
• Hybrids and reverse hybrids – potential candidates for distributor entity

12:15 pm LUNCHEON

1:30 pm U.S. Workshop Chair:

WORKSHOP 1 (Canadian Tax Practitioners) - Minimizing State Income and Sales Taxes

• Understanding state tax nexus and jurisdiction issues – when is a company required to file a tax return?
• Separate vs. combined or unitary reporting - use of holding companies and other tax efficient structures for reducing state taxes
• State tax issues in tax-free acquisitions and reorganizations
• Special state tax issues, including sales and use tax, royalty income and intangible licensing issues

WORKSHOP 2 (U.S. Tax Practitioners)

• Ontario Harmonization, GST, HST and other Canadian Sales Taxes
• Review of key concepts and transitional rules for replacement of Ontario Retail Sales Tax with Harmonized Sales Tax
• Review of other GST and Canadian sales tax current topics

2:30 pm Refreshment Break

2:45 pm WORKSHOP 3 (Canadian Tax Practitioners) - Corporate Tax Planning for Canadian-Owned U.S. Companies in 2010

• 2010 tax developments- Extension of NOL carryback, bonus depreciation, FBAR reporting rules
• Consolidated return update - SRLY and CRCO limitations
• Amortization of intangibles and software
• Tax transparency

WORKSHOP 4 (U.S. Tax Practitioners) - Corporate Tax Planning for U.S.-Owned Canadian Companies in 2010

• Managing inter-company transactions without consolidated tax filings - planning for the use of losses
• Understanding the corporate tax benefits in Canada's 2009 Economic Action Plan
• How Canadian subsidiaries can take advantage of the low corporate tax rates in Canada
• Use of Canadian hybrid entities (such as NSULCs)

4:00 pm WORKSHOP 5 (Canadian Tax Practitioners) - Acquiring and Restructuring U.S. Operations

• Stock v. asset acquisitions - latest Sec. 338 election strategies for stepping-up the basis of acquired assets
• Taxable v. tax-free acquisitions strategies - understanding the U.S. rules for acquisitive A reorganizations and mergers of hybrid entities
• Recent trends in domestic reorganizations and liquidations – step transaction doctrine
• Understanding the U.S. tax rules under Sec. 367 for cross-border acquisitions, liquidations and restructurings

WORKSHOP 6 (U.S. Tax Practitioners) - Acquiring and Reorganizing Canadian Operations

• Acquisitive transactions from the buyers'/sellers' perspective – taxable v. tax-free transactions
• Elections and tax reporting requirements for acquisitions in Canada – post-acquisition planning
• Understanding the rules in Canada for tax-free reorganizations, including amalgamations, spin-offs and split-ups
• Winding-up a Canadian corporation or partnership

5:15 pm Meeting Adjourns for the Day

Tuesday, October 19th

8:00 am Continental Breakfast

8:15 am WORKSHOP 7 - Preparing Form 1120-F

• Reporting the results of a Canadian company with U.S. activities
• Review of latest Form 1120-F and supporting schedules
• Applying for a U.S. TIN and disclosure of foreign bank account data
• Understanding the U.S. withholding tax system – filing U.S. tax forms – W-8, 1042 and 8833

9:30 am Refreshment Break

9:45 am U.S. and Canadian Taxation of Executives Performing Cross-Border Services

• Latest individual tax issues in Canada and U.S.
• How U.S. and Canada tax non-resident income – tax treaty implications for individuals
• Taxing active v. passive income on capital and loans
• Treatment of full time v. part time services - immigration issues

11:00 am Current Strategies for Financing U.S. and Canadian Operations

• Avoiding thin capitalization issues on cross-border lending activities – maximizing interest expense benefits
• Designing financial products to minimize the U.S. earnings stripping limitation under Sec 163(j)
• Latest strategies for reducing U.S. and Canadian withholding taxes and related compliance issues

12:30 pm LUNCHEON

1:30 pm Tax Accounting Update for Canada-U.S. Operations

• Current issues in reconciling the statutory and effective tax rate for Canadian/U.S. multinational operations
• Tax accounting rules on mergers and acquisitions - understanding the rules for goodwill under FAS #141/142
• Understanding how FIN 48 affects tax provision planning
• Update on IFRS conversion in Canada and the impact on income tax provisions in 2009 and 2010

2:45 pm Refreshment Break

3:00 pm Repatriating Earnings from Canadian and U.S. Affiliates and Cross Border Tax Minimization Strategies

• Understanding the surplus capital rules in Canada
• Tax issues involving cross-border royalty and technology transfers – interrelationship with the latest IRS service rules
• Understanding the affects of the latest U.S. international tax rules
• Dividends paid directly by U.S. or Canadian subsidiaries and through intermediate companies
• Understanding how the US Subpart F and Canadian FAPI rules apply

5:00 pm Meeting Adjourns

Canada - U.S. Transfer Pricing Symposium

Wednesday, October 20th

7:30 am Registration and Continental Breakfast

8:30 am Welcome and Chair Introduction

8:45 am Trends in Canada and U.S. Transfer Pricing Rules

• Review of transfer pricing methodologies in Canada – comparison of Canada, OECD and U.S. requirements
• Use of transfer pricing studies for satisfying the documentation requirements
• Comparison of TP policies and penalty provisions in Canada and the United States
• Impact of recent tax decisions

9:45 am Refreshment Break

10:00 am U.S. Transfer Pricing Strategies for Canadian Companies

• Optimizing global transfer pricing compliance costs
• Reconciling U.S. & Canadian methodological differences
• Managing foreign exchange and sales finance issues in uncertain economic times
• Application of U.S. services regulations for Canadian headquartered companies

11:00 am Refreshment Break

11:15 am Hot Transfer Pricing Issues in Canada for U.S. Companies

• Transfer pricing in a down economy
• Royalties - know-how and cost contribution arrangements
• Business restructuring - plant closures/IP migration
• Cost sharing and intangible transfers
• Recharacterization
• Services/permanent establishments
• 247(4) documentation letters
• Financial transactions and guarantee fees
• Transfer Pricing Review Committee (TPRC)

12:15 pm LUNCHEON

1:15 pm Administrative Resolution of Cross-Border Transfer Pricing Disputes

• Assessing the Options to get Resolution
• Pros and cons of how Advance Pricing Agreements (APAs) can be used to assist in resolving audits
• Latest developments, strategies and policies in Appeals and Competent Authority
• Key steps to the Appeals and Competent Authority Process

2:45 pm Refreshment Break

3:00 pm Recent Jurisprudence

• Review of current case law in Canada and the U.S.

4:15 pm Closing Comments – What You Should Take Home From This Meeting

4:30 pm Meeting Ends

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