Cross-Border Personal Tax Planning
May 21 & 22, 2013, Toronto
Cover all your bases and avoid excess taxation
Workshop Included: Tax planning for snowbirds retiring in the U.S.
Alpesh Joshi, Alpesh Joshi CA Professional Corporation
Alpesh Joshi is Managing Director at Alpesh Joshi CA Professional Corporation. With over 10 years of experience in private and public practice, his practice focusses on pro- viding accounting, audit and tax services.
Two-Day Event! “Lots of good information that I can use.”
“Very practical suggestions.”
Participating Organizations
- Aird and Berlis LLP
- Alpesh Joshi CA Professional Corporation
- Glenn M. Davis Insurance and Estate Consulting
- Gowling Lafl eur Henderson LLP
- Keel Cottrelle LLP
- KPMG LLP
- Manulife Financial McMillan LLP
- Miller Thomson LLP
- PricewaterhouseCoopers LLP
- Thorsteinssons LLP
Who should attend
Lawyers in Tax Planning, Lawyers in Estate Planning, Financial Planners, Investment Planners and Tax Accountants who want to expand their knowledge area or keep up-to-date in this field
Course highlights
- Cross-border estate planning strategies
- Overview of the U.S. estate and gift tax structure
- Critical tax planning issues for U.S. citizens in Canada
- Latest tax issues affecting non-resident investors in U.S. real property
- The U.S.-Canada tax treaty protocol
- Tax planning for Canada-U.S. employment transfers
- Tax planning for your cross-border family business
COURSE PROGRAM
TAX PLANNING FOR U.S. CITIZENS IN CANADA
U.S. citizens in Canada must carefully plan their move in order to ensure compliance with relevant laws and requirements. Adding to the complexity to this planning, is that these individuals often retain property or business interests in the U.S. and still have taxation obligations there. This session explores tax issues and planning opportunities for U.S. citizens in Canada.
- Critical tax planning issues for U.S. citizens in Canada
- Use of an offshore immigration trusts in tax planning
- Avoiding double taxation risks: foreign tax credits issues
- Tax treaty implications
- Disclosure requirements
TAX EFFECTIVE CROSS-BORDER WILL PLANNING
While many wills are straightforward, there are intricate tax strategies that come into play in cross-border will planning involving beneficiaries, assets, trustees in different jurisdictions. This session covers efficient financial, legal and taxation issues involved in cross-border will drafting and how to ensure you cover all your bases and avoid excess taxation.
- U.S. tax-saving opportunities in will planning
- Tax effectively addressing issues involving beneficiaries, assets, trustees in different jurisdictions
- Changes to U.S. law affecting will planning
- Post mortem impact that U.S. taxes have on estates, trusts and beneficiaries
TAX IMPLICATIONS OF CANADIANS BUYING, SELLING AND RENTING U.S. REAL ESTATE
Non-resident must be aware of the tax consequences of buying selling and renting U.S. real estate in order to take advantage of tax planning opportunities and to avoid paying excess taxes. This session will examine the latest tax issues affecting non-resident investors in U.S. real property.
- Review of tax rules generally applicable to non-residents investing in U.S. real estate
- Pros and cons of various ownership structures involving non-residents
- Minimizing tax liability on rental income and capital gains earned by non-residents in the U.S.
- Tax considerations for Canadians owning U.S. rental properties
- Estate tax law and U.S vacation homes
THE U.S.-CANADA TAX TREATY PROTOCOL
Since being signed in 1980, the Canada-US Tax Convention has been revised a number of times. The Fifth Protocol included important changes that affect cross-border estate planning in such areas as charitable donations, taxes imposed by reason of death on RRSPs and U.S. stock options. This presentation will provide an overview of its impact and look at tax planning opportunities.
- Rules dealing with residence: U.S. residency issues, snowbirds and treaty provisions
- Tax planning opportunities in light of the changes
- Impact on foreign tax credit rules & withholding taxes
- Tax consequences of migration
- Exemption of certain income
TRUSTS & ESTATE PLANNING FOR U.S. BENEFICIARIES
Canadians whose spouses or children are U.S. citizens or residents must consider U.S. estate taxes in order to take advantage of all tax saving opportunities. This session will focus on tax effective estate planning strategies for families that include U.S. residents/citizens.
- Outright bequests to U.S. children
- Bequests to testamentary trusts for U.S. children: testamentary trusts and U.S. estate tax
- Trust residency: foreign trust rules and the 21-year rule
- Alter ego trusts and joint spousal/common-law partner trusts
- Cross-border tax planning using family trusts: trusts for children and grandchildren trusts
CANADIAN & U.S. EXPATRIATION RULES
Seeing that expatriating can be used as a method to reduce personal taxation, Canada and U.S. tax law includes sanctions for citizens who have expatriated. This session will examine Canadian and U.S. expatriation rules and income and estate tax planning techniques for individuals who are considering expatriating.
- How to become an expatriate
- Deemed disposition of all property: calculating your capital gains or losses
- Exceptions of deemed dispositions: types of properties
- Deferring the tax owing on a deemed disposition
- U.S. Mark to Market Tax
INSURANCE CHOICES & TAX IMPLICATIONS
Estate and personal tax plans typically do not contemplate the life insurance needs of business owners or high net-worth individuals. This discussion will focus on the design and tax treatment of more innovative insurance programs that can be used in cross-border personal tax planning purposes.
- Shared insurance arrangements
- Leveraged insurance programs
- Business succession insurance
- Donation of insurance
Insurance Choices and Their Tax Implications
Joel Cuperfain, B.A., LL.B., LL.M., CLU, TEP
RBC DS Financial Services Inc.
Charitable Gift Planning
M. Elena Hoffstein
Fasken Martineau DuMoulin LLP
Tax-Efficient Use of Life Insurance
Robin D. Goodman
RBC Financial Group
International Wealth and Tax Planning
Shona N. Stone
UBS Bank (Canada)
Cross-Border Estate Planning
Marina Panourgias
Deloitte & Touche LLP
Wills: Litigation
Brian E. Cohen
Borden Ladner Gervais LLP
Succession planning in the Family Law context
Clare A. Sullivan
Aird & Berlis LLP
The Use of Trusts in Estate Planning
Corina Weigl
Fasken Martineau DuMoulin LLP
Post-Mortem Tax Planning Strategies
Rachel Blumenfeld
Miller Thomson LLP
Succession and Tax Planning for
Owner-Managers
James W. Kraft, , CA, CFP, CLU, TEP
BMO Life Assurance Company
Recent Developments in US Tax & Compliance Matters
Terry Ritchie
Transition Financial Advisors Group
Estate Planning for Spouses/Couples
Jennifer Lamb
Borden Ladner Gervais LLP
Wills: Avoiding Excess Taxation
Clarke Barnes
Fasken Martineau DuMoulin LLP
International Wealth and Tax Planning
Peter C. Myers
PricewaterhouseCoopers LLP
Advanced Income Tax Planning for Maximizing Asset Protection
William J. Fowlis
Miller Thomson LLP – Calgary
The Unique Role of Life Insurance in Succession planning
Malcolm Scarratt
Scarratt Estate & Succession Planning, Inc.
Owner-Manager Tax Planning
Kate S. Marples
Legacy Tax + Trust Lawyers
Taxation of Investment & Retirement Income (TFSAs)
Fred Purkey
Davies Ward Phillips & Vineberg LLP
Use of discretionary Trusts for Tax Planning and Creditor Proofing
David W. Ross
Burnet Duckworth & Palmer LLP
U.S. Income Tax Planning: Recent Developments
Janette Zive
PricewaterhouseCoopers LLP
Exposure to the U.S. Gift and Estate Tax Regime
Peter Megoudis, BCL, LL.B., LL.M.
Deloitte & Touche LLP
Creating Offshore Structures
Peter C. Myers
PricewaterhouseCoopers LLP
Minimizing Departure Tax: Deemed Dispositions of Property
David P. Stevens
Gowling Lafleur Henderson LLP
Canadian and US Repatriation Strategies –
Returning to Canada
Leah C Shinh
Ernst & Young LLP
The U.S. – Canada Tax Treaty Protocol: Impacts and Planning Opportunities
Michael W. Domanski
Honigman Miller Schwartz and Cohn LLP
Novotel Toronto Centre Hotel, 45 The Esplanade, Toronto, ON, M5E 1W2
May 14, 2013
WORKSHOP
TAX PLANNING FOR SNOWBIRDS RETIRING IN THE U.S.
Individuals who are planning a retirement in the U.S. must carefully consider the tax implications of such a move in order to fully benefit from effective tax planning and prevent spoiling their comfortable retirement. This session will examine tax planning for retiring in the U.S.
- Departing Canada
- Residency Issues
- Tax and Cash flow planning for living in the U.S.
- Taxation of retirement income in Canada and the U.S.
- Tax effective investment planning for your retirement investments
- U.S. taxation of RRSPs, RRIFs LIRAs
- U.S. taxation of pensions
- FBAR Foreign Bank and Financial Accounts
- Owning US Vacation home
MULTIMEDIA
Your registration includes an interactive multimedia CD-ROM comprising the following presentations from recent Federated Press courses and conferences.
They are presented in their entirety with complete audio and accompanying slides.
For an additional $175 to the registration fee, you can receive the multimedia proceedings of the course on CD-ROM, containing all presentations given at event.
If not registered for the event, the cost of this CD-ROM, which also includes the presentations described below, is $599.
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 May 7, 2013. No refunds will be issued after this date.
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:
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.
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
Phone: 1-800-363-0722 Toronto: (416) 665-6868 Fax: (416) 665-7733
Alpesh Joshi 