Learn how to keep planning effective under enhanced GAAR, reporting rules and tougher CRA powers, with practical tips on documentation, privilege, disputes and estate planning.
Tax planning in Canada has never been more challenging. Enhanced GAAR penalties, the reportable and notifiable transaction rules, expanding CRA audit powers and ever-widening reporting obligations all affect how practitioners plan and document transactions. In this interactive panel, tax and estates lawyers work through the issues most relevant to practice today, combining recent case law with practical takeaways and live audience questions.
The session opens with the current planning environment: the chilling effect of the enhanced GAAR, how reporting under the mandatory disclosure rules can interact with voluntary GAAR disclosure, and a recent Federal Court of Appeal decision that emphasizes the text of the Act when interpreting it. It then covers a key Federal Court of Appeal decision on dividends paid through a family trust to a corporate beneficiary, why the timing can trigger Part IV tax in pre-sale planning (the Supreme Court of Canada has declined to hear an appeal), and how to plan around it, including the impact on capital dividend account planning.
The panel then looks at whether a surviving spouse can be held liable for a deceased spouse’s tax debt under section 160, and what that means for RRSP beneficiary designations and clearance certificates. It covers fixing past transactions and compliance errors: when doing nothing is an option, the revised Voluntary Disclosure Program, memorializing undocumented agreements, and why backdating can lead to gross negligence and third-party penalties.
Further topics include solicitor-client privilege in tax planning (including why there is no accountant-client privilege, and how AI note-takers can waive privilege), lesser-known dispute options such as judicial review, remission orders and the Tax Court’s informal procedure, and the newly enacted changes to the section 44.1 capital gains deferral for small business shares. The session ends with a lightning round on 21-year rollouts from trusts, price adjustment clauses and reassessment periods, and common pitfalls in passing assets to the next generation.
1 activity • 1 videos • duration: 1h 30m
The CPA Small Practitioners’ Forum was created to offer an inviting, semi-causal, and easygoing professional development weekend that provides substantial professional development value to small practitioners. All profit earned by the CPA Small Practitioners’ Forum is donated to the Alberta CPA Education Foundation, so you are helping young people in Canada get scholarships for university. All these courses are reviewed by the delegates at the Forum in Banff annually so we have a great lineup that is adjusted every year to keep things relevant to small practitioners. If you work at a public accounting firm in Canada with employees of 1-50 people, you are our target demographic and you should find this course useful.
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