David-Alexandre will present an overview of the Canadian economy. He will explore the current trade and geopolitical situations and cover their implications. He will also discuss challenges and opportunities facing our economy and as well as discuss the economic outlook.

It is difficult to identify a period in living memory in which the global tax environment has been as turbulent as it is the moment.  U.S. actions in particular – on tariffs, on retaliatory income tax measures, on the OECD “Pillars”, and in advancing a significant tax bill – have immense implications for Canada’s and other countries’ tax systems, and the investment environment more generally. 
 
The panelists will provide their insights on the direction and ramifications of global tax developments, concluding with a discussion of the influence of both international and domestic considerations on the changes to the Canadian tax system we are likely to see in the “new” Canadian government’s first budget this fall.

A dynamic 60-minute mock trial demonstration of the courtroom experience, including insights from a former Tax Court of Canada judge, Hon. Patrick Boyle. The session is designed to provide the audience with a view into what really happens in Court and how judges may perceive those events.

Witness: Special Guest

This session will focus on how to set yourself up for victory in Tax Court (or avoid litigation altogether) at the audit and appeals stages.

This session will examine recent income tax cases focusing on a variety of substantive and procedural issues.

This session will provide perspectives from both the Bench and the Bar on the resolution of tax disputes.

Host:
Kyla Zhao, Vice President, Taxation, Canada Life

Join us for a memorable evening under a grand tent nestled beside the picturesque vineyards of Château des Charmes. Shuttles to/from the hotel and the venue will be provided.

Host: 
Bruno Mercier, Senior Director, Taxation, Industrial Alliance

This session will explore life insurance sales trends and emerging market applications for universal life and par products. The speakers will also address the growth of leveraged life insurance and highlight the ongoing opportunities and related issues with this marketing strategy.   

Life insurance continues to be a critical estate planning tool for policyholders and their corporations. This presentation will delve into the following topics:

1.    Corporate owned life insurance – the macro tax environment has led to increased tax deferral.  Tax deferral is not tax elimination and can lead to double/triple taxation when a shareholder passes away.  Post mortem planning can provide relief to these multiple layers of tax.  This part of the presentation will review updates on post mortem planning including proposed rule changes and updates to CRA positions. Additionally, this presentation will review the impact of structuring corporate beneficiary designations properly in the corporate context to minimize the risk of benefit issues applying. 
2.    Life insurance ownership including bare trusts – This portion of the presentation will discuss some of the considerations and scenarios with different types of ownership,  and transferring ownership. There has been greater interest in the use of bare trusts and nominee corporations in recent years. Additionally, there will be a discussion around tax reporting for the late notification of death for owners and corporate owned life insurance. 

A breakout discussion on a variety of technical items affecting segregated funds, annuities, and nonresidents. Topics will include EIFEL considerations, Qualified Investment rules, and various examples of situations involving a nonresident of Canada owning or insured under a life insurance policy.

Speakers will discuss the global roll-out of Pillar Two legislation (with a focus on jurisdictions most relevant to insurers), and how Pillar Two is influencing the global tax landscape and tax strategies of large multinational insurers.

This panel will focus on sales tax considerations in M&A transactions, including foreign direct primary investments and zero-rating, partnership issues and reorganizations. We will also provide a sales tax case law update.

The panel will discuss the hot indirect tax issues from an advisory and industry perspective. This includes outlining the following matters: (i) the recent legislative changes; (ii) changes in CRA’s interpretive position; (iii) the indirect tax issues being raised at audit and the practical ways to address the issues; and (iv) outlining the takeaways from the relevant jurisprudences.

This panel will discuss recent U.S. corporate tax developments of primary importance to inbound insurance groups, with a particular focus on legislative and regulatory developments impacting U.S. operations and repatriation efforts.  During our discussion, we aim to guide tax professionals through these developments by summarizing the contemplated scope of each new item, highlighting principal points of consideration, and offering practical approaches to implementing new guidance at an organizational level.  We also intend to level-set on the current state of the corporate alternative minimum tax (CAMT) and the stock repurchase excise tax, among other topics.

This session will provide insight on some of CRA’s new trending positions affecting insurance industry, including background, CRA’s position, and practical tips to improve your chances of success.

This session will explore the evolving transfer pricing environment, key areas of challenge, and areas for insurers to consider in relation to supporting transfer pricing policies after they have been established.

Please join us as CRA Industry Specialist discusses CRA’s approach to insurance audit and how Industry Specialists Services can be of assistance.  Discussion of IFRS 17 from the CRA Perspective, including their training progress for audit staff, administrative changes you may have seen at CRA and other compliance matters of interest.

Host:
Bruno Mercier, Senior Director, Taxation, Industrial Alliance 

Meeting point is Queen's Landing hotel lobby

Host:
Debby Langridge, Director, Taxation, Manulife

This is a Q&A session involving a variety of interpretive income tax issues.

AI is rapidly transforming the way organizations and their tax teams operate, drive insights, and add value.  But how can tax teams move from curiosity to experimentation to operationalization?  In this session we will explore how tax teams can successfully and effectively leverage AI and demystify the real-world applications of AI in tax from use cases through to integrate within your tax operating model.  This session will also include a fireside chat discussing how to tackle the legal, ethical, and governance considerations surrounding AI adoption and how tax teams can address risks, safeguard compliance and drive responsible innovation.  Whether you’re AI-curious or already piloting tools, this session will give you the insights and confidence to take the next step.

This session provides an update on current anticipated changes on FATCA/CRS requirements in Canada as well as an overview of compliance enforcement activities by the CRA and latest trends in global enforcement.

Capital tax levied on financial institutions, whether federal or provincial, represent an insidious risk to a life insurer’s effective tax rate. Capital taxes represent a floor on permanent deductions from income tax and restrict tax value from planning opportunities. More dramatically however, is the looming existential threat of significant deferred tax asset write-offs where capital tax prevents a reasonable forecast for utilization. This session will cover briefly the history of capital tax, current application by federal and provincial authorities, the major components driving capital tax liability, and past and present considerations for managing capital tax exposure.

Host:
Christine Walter, Chair, TOS Executive Committee