Covering current tax topics, these seminars are set at a high technical level so you can learn the latest tax planning ideas and tax legislative information. Click on topic for an overview and detailed outline.

Please note that this seminar is for professionals looking to gain in-depth knowledge on tax compliance. If you are looking for our free public presentations on US tax and filing for Canadian residents, go to Public US tax presentations.

1. Canadian Update
   1. Partnership deferral collapse implications – new sections 34.2 and 34.3
   2. T5013 update
   3. T3 update
   4. T2 update
   5. T1 update
   6. Misc. reporting form updates (T4’s, T4A, NR4, T5, etc.)
   7. Other reporting forms update (non-exhaustive)
      • CPT20 and CPT30 – Election to Pay CPP and Election/Revocation to Stop Contributing to CPP
      • RC257 Request for Information Return Program Account (RZ)
      • RC298 Advantage Return for TFSA Issuers
      • RC310 Special Relief Election for Under-water Stock Options
      • T1-OVP 2011 Individual Tax Return for RRSP Excess Contributions
      • T626 Overseas Employment Tax Credit
   8. Foreign reporting forms update
      • Payments to Non-Residents – T4A-NR, NR4
      • New Treaty Benefit Declaration Forms – NR301, NR302, NR303
      • Clearance Certificate Requests – T2062, T2062A, T2062B, T2062C
   9. Failure to file little known forms
      • T1161 List of Properties by an Emigrant of Canada
      • T1243 Deemed Disposition of Property by an Emigrant of Canada
      • T5004 Claim of Tax Shelter Loss or Deduction
      • T2091 Designation of Property as a Principal Residence by an Individual
      • T1159/NR6 – Re: Section 216 NR Payment of Tax on Net Rental Income
      • T2022 Election in Respect of the Sale of Debts Receivable
      • T1213 Request to Reduce Tax Deductions at Source
2. US Update
   1. Who needs to file US reporting forms?
   2. Common reporting forms
   3. New reporting forms
   4. What to do if US person is not compliant?
   5. PTIN
3. Foreign Tax Credits
   1. Eligibility for FTC claims
   2. How FTC’s are properly reported?
   3. Common errors

1. US Immigration Planning Overview
   1. Reconciling immigration and tax objectives
   2. Nonimmigrant visas and the Substantial Presence test for tax residency
   3. Permanent resident status and the Green Card test for tax residency
   4. Permanent resident status and the Exit Tax
2. Nonimmigrant Visa Options
   1. Business Visitors and Tourists
   2. TN under NAFTA
   3. H-1 based on education or work experience
   4. L-1 for intracompany transferees
   5. E-1 for substantial trade and E-2 for substantial investment
   6. O-1 for athletes, entertainers and others with extraordinary ability
   7. Visas that provide exemption from Substantial Presence test
3. Permanent Resident Status through Family Sponsorship
   1. Spouse, parent or child of US citizen
   2. Spouse or child of permanent resident
   3. Brother or sister of US citizen
4. Permanent Resident Status through Employment and Labor Certification
   1. Labor certification to test the US job market
   2. Advanced degree professionals
   3. Skilled workers and professionals
   4. Unskilled workers
5. Permanent Resident Status through Employment without Labor Certification
   1. Extraordinary ability
   2. Outstanding professors and researchers
   3. Multinational executives and managers
6. Permanent Resident Status through Investment
   1. $500,000 or $1,000,000 equity investment
   2. Sole owner or multiple owners
   3. Active or passive owner
   4. Create or preserve 10 jobs per investor
   5. Indirect job creation through Regional Center
   6. Conditional resident status for 2 years
7. Permanent Resident Application Process
   1. Labor Certification, if needed
   2. Immigrant Visa Petition
   3. Adjustment of Status or Immigrant Visa Application
   4. Converting conditional resident status to permanent resident status
8. Green Cards and the Exit Tax
   1. Long-Term Residents, Expatriates and Covered Expatriates
   2. Revocation or Abandonment of permanent resident status
   3. Maintaining permanent resident status while residing abroad
   4. Surrendering permanent resident status before becoming Long-Term Resident
   5. Switching to nonimmigrant visa status before becoming Long-Term Resident
   6. Switching to US citizenship to avoid abandonment of permanent resident status
9. SURPRISE! Your Client May Be an American Citizen and Not Know It
   1. Citizenship by birth in the US
   2. Citizenship by birth abroad to US citizen parent
   3. Naturalization and derivative naturalization of children
   4. Retroactive presumption of intent to retain US citizenship
   5. Three generations of Accidental American Citizens
   6. How to spot Accidental American Citizens
10. Terminating American Citizenship
    1. Confirm or acquire another citizenship
    2. Obtaining citizenship through investment
    3. Plan for travel without US passport
    4. Understand consequences of expatriation
    5. Confirm not "excludable" from US on criminal or medical grounds
    6. Understand Reed Amendment exclusion ground for tax expatriates
    7. US immigration planning – visiting, working or residing in US
    8. Renunciation, Relinquishment and other means of expatriation
    9. Difficult cases – children, young adults or diminished mental capacity
    10. Procedure and timing for terminating citizenship

1. Federal Budget and Other Tax Changes Of Relevance During the Recent Past
2. Tax Rate Changes
   
   1. Overall review
   2. Updates
3. Eligible Dividends
   1. CRA Technical Interpretations
   2. Bonus vs. No-Bonus
   3. Estate planning overview using eligible dividends
4. What’s New in Case Law that Affects Owner-Manager Taxation?
   1. Brief review of recent case law
5. Planning
   1. Review structures/shareholdings
   2. Recent planning ideas
   3. Loss utilization
   4. Other
6. Other Remuneration Strategies
   1. Repatriating tax attributes
   2. Interest on shareholder loans
   3. Capital gains
   4. Other

1. Overview
   1. Planning process
   2. Goals
   3. Legislative constraints
   4. 2012 tax rates
   5. Probate fees
   6. Land transfer fees
2. Will Planning
   1. Avoiding probate taxes
   2. Avoiding or deferring capital gains taxes
   3. US estate tax matters
   4. Accessing privacy
   5. Multiple wills
   6. Beneficiary designations
   7. Spousal trusts
   8. Asset protection trusts
   9. Loss carryback vs. “pipeline” and recent CRA comments regarding subsection 84(2)
   10. Standard or “simple” wills rethought
   11. New Wills and Succession Act
3. Enduring Powers of Attorney
   1. Defined
   2. Advantages
   3. Disadvantages
   4. Different types
   5. Conflict of laws
   6. Revocation
   7. Liability
   8. Landscape elsewhere in Canada
4. Living Wills / Personal Directives
   1. Defined
   2. Advantages
   3. Disadvantages
   4. Health care decisions
   5. Landscape elsewhere in Canada
5. Trusts
   1. Discretionary
   2. Non-Discretionary
   3. Alter Ego and Joint Partner Trusts
   4. “Self Benefit” Trusts
   5. Asset Protection Trusts
   6. Wealth Accumulation Trusts
6. Succession Planning
   1. Estate freeze
      1. Basic
      2. Variations and alternatives
   2. Valuing voting vs. non-voting shares
   3. Asset protection
   4. Business division equalization
   5. Creating equalization assets out of retained earnings
   6. Safe income freeze buyouts
   7. Shareholder agreements
   8. Spinouts and butterflies
   9. Capital gains exemption and crystallization
   10. Basic uses of life insurance
7. Freeze Alterations
   1. Melts
   2. Thaws
   3. Refreezes
   4. Reverse freezes
   5. Downstream freezes
   6. Variations of trusts
   7. Trust distributions
8. Income Splitting
   1. Corporate attribution rules
   2. Exceptions to corporate attribution rules
   3. Exemption for estate freezes
   4. Startup situations
   5. Kiddie tax
   6. Personal attribution rules
   7. Exceptions to personal attribution rules
   8. Tax traps
   9. Planning opportunities
   10. GAAR and income splitting
9. Charitable Giving
   1. General rules
   2. Inter vivos
   3. Will
   4. After tax cost of giving cash
   5. After tax cost of giving property
10. GST Matters

1. Inbound Investment into Canada by US Persons
   1. Canadian corporation
   2. Canadian ULC (Alberta, BC, NS)
   3. Canadian partnerships
   4. Canadian branch
   5. GST/HST considerations
   6. Sub-part F
2. Outbound Investment into US by Canadians
   1. Canadian corporation
   2. Canadian partnership
   3. US C-Corp
   4. US LLCs
   5. US partnerships
   6. State/local tax considerations
   7. FAPI matters
3. Repatriation Matters
   1. Avoidance of double taxation
   2. Maximizing surplus “up the chain”
4. Financing the Investment
   1. Interest deductibility
   2. Thin capitalization
   3. Debt vs. equity
   4. Repatriating the investment – how?
5. Permanent Establishment Issues
   1. What is a PE?
   2. Case law review
   3. Recent CRA Technical Interpretations and OECD activity
   4. Structural considerations
6. Transfer Pricing Considerations
   1. Section 247 review
   2. CRA considerations
   3. IRS considerations
7. Personal Use Real Estate Investment into the US
   1. Substantial presence test
   2. Estate tax considerations
   3. Ownership options