What you need to know now about US/Canada cross-border taxation
Day 1: 30 January 2020
9.30 Chairman’s introduction: Peter Megoudis, Trowbridge Professional Corporation
9.45-10.45am Federal & state tax update: Grant Campbell & Romana Fabicka, BDO
11.10am-12.00pm PFICs – Update on classification of Canadian pooled funds: Max Reed, SKL Tax
12.00-12.50pm Green Card Holders, Tax Treaty Tie Breakers and more: John Richardson, Citizenship Solutions
1.50-2.40pm Tax without cash in Canada and the US – wealth, compensation and other examples: Peter Megoudis, Trowbridge Professional Corporation
2.40-3.30pm Expatriation procedures – compliance before, or after?: Leslie Kellogg, Hodgson Russ
4.00-5.00pm Panel: Planning ahead: Canadians moving to the US; Americans moving to Canada – what needs to be done? Led by Michael Koenig, Davis Martindale
5.00pm Drinks reception
Day 2: 31 January 2020
9.30 Chairman’s introduction: John Richardson, Citizenship Solutions
9.35-10.25am Gift and estate tax for aliens: Peter Megoudis, Trowbridge Professional Corporation
10.50am-11.40am Mitigating IRS penalties: Max Reed, SKL Tax
11.40-12.30 Keynote address: Monte Silver
1.50-2.45pm Sections 959, 960 and 962: On the periphery of Subpart F: Ray Kinoshita, Grant Thornton
2.45-3.35pm Reducing double tax problems through FTCs: Ian Macdonald, CPA
4.00-5.00pm Ethics and compliance – What exactly are your obligations to a client? John Richardson and Peter Megoudis
5.00pm Review and close
Hear from the experts on Canada/US cross-border taxation
Trowbridge Professional Corporation
Peter Megoudis provides a wide variety of cross-border (US and Canadian) tax services, including advising High Net Worth clients on corporate, trust, and personal structuring of their businesses, trust and estate planning, and trust and personal tax filings and compliance. He also advises individuals on tax planning and compliance implications of leaving or entering Canada, or expatriating from, or leaving, the US; as well as assisting them in US or Canadian Voluntary Disclosure applications. He also consults with both companies and executives on designing deferred compensation plans, and determining compliance with US and Canadian compensation rules.
He has over 20 years of experience as a Partner in a big four firm in their Global Employer Services Group and the cross-border tax field, and has published extensively on both HNW and compensation areas, and is a frequent speaker at conferences and forums.
John Richardson is a Toronto-based lawyer and a dual US/Canada citizen. He provides citizenship counselling for US citizens and around the world. John is also a member of the American Citizens Abroad Professional Tax Advisory Council (PTAC). He writes and speaks regularly on all matters relating to taxation and citizenship and is frequently interviewed on such matters for broadcast.
Grant Campbell & Romana Fabicka
Romana Fabicka joined BDO in 1996, and has specialised in Canada–US cross-border taxation since 2003. She deals with a wide variety of clients in that capacity, focusing on individual, trust and estate tax matters. Romana regularly leads US tax planning and compliance projects for US citizens living abroad to ensure the proper tax treatment of their financial activities. As a US tax professional operating in a foreign country, Romana has the extensive expatriate technical experience to help her clients with foreign reporting obligations and structure their personal and estate affairs in an optimal manner.
Grant Campbell joined BDO in 2010 specialising in Canada – U.S. cross-border taxation. His primary focus is the cross-border taxation of individuals; working with various clients from across the country. Grant is actively involved in the development of policies and standards for BDO’s Canadian national U.S. tax practice. He has presented cross-border tax topics at conferences for BNA | Bloomberg CITE.
Max Reed solves tax problems that span both sides of the Canada-US border including: Advising corporations on the US tax implications of cross-border transactions and initial public offerings; Helping US citizens in Canada deal with US tax issues including renouncing their US citizenship; Developing estate and tax plans that work on both sides of the border; Advising Canadian investment funds on investments into the United States and receiving investments from US taxpayers.
Max is the co-author (with Dick Pound of Stikeman Elliot) of A Tax Guide for American Citizens in Canada, as well as over 20 technical and plain language articles on a wide range of cross-border tax topics.
Max regularly speaks at conferences and seminars for tax professionals and the general public. He was invited to testify before the Canadian House of Commons Finance Committee on the impact of US tax law on Canadians.
Prior to joining SKL, Max worked at an White & Case LLP, an international law firm in New York City where he provided US tax advice to individuals, corporations, and foreign states.
He holds a BA and two law degrees from McGill University, where he won a number of academic and leadership awards, and is admitted to the bars of BC and New York.
Ian Macdonald is a sole practitioner practising in the areas of Personal Income Taxation and Financial Planning. He is a Chartered Professional Accountant and a Certified Public Accountant, as well as a Certified Financial Planner in both Canada and the United States. He graduated from the University of Western Ontario and the University of Windsor, and is a seminar leader at the CPA Canada's In-Depth Tax Course and an instructor at the Orientation, Research and Communications Course.
Prior to forming his own practice, Ian was for many years a senior manager in PwC’s Human Resource Services (“HRS”) practice in Toronto leading their Cross Border Private Client offerings. Ian has extensive experience advising clients on the cross border (including Canadian and U.S.) tax issues related to investments, incentive compensation plans and pensions, as well as the application of income tax treaties to prevent double taxation.
Michael Koenig achieved his CGA designation in 1984 and Certified Financial Planner designation in 2000. He joined Davis Martindale as a partner in 1999 after many successful years running his own independent practice. His focus is on USA and international cross border tax compliance, planning and preparation. Michael’s practice focuses on a wide spectrum of client business, tax and accounting services. He is an expert in financial tax and planning support for owner-managed businesses, personal and corporate tax planning and preparation, and cross-border tax compliance.
Ray Kinoshita has focused since 1997 primarily on US tax matters for Canadian businesses investing in and sending employees to the United States and for US businesses investing in and sending employees to Canada. Previously, he specialised for 15 years in Canada-US cross-border tax matters, including structuring of cross-border investments and planning for tax-efficient financing in both directions, both for corporations and for individuals. During a two-year secondment in Europe, he gained a greater global perspective on international tax considerations.
Leslie Kellogg practises in a wide range of U.S. and international tax areas. She counsels clients on advantageous business structures for tax and estate planning purposes. Leslie has a particular focus on helping high-net-worth families manage estate planning goals in multiple jurisdictions. Her practice often focuses on cross-border matters, including structuring considerations in purchasing U.S. real estate, business expansion into the United States, tax considerations in private and public offerings, and the application of the U.S. anti-deferral regimes. She also regularly counsels clients on U.S. tax compliance matters as well as the ramifications of relinquishment of U.S. citizenship or lawful permanent ("green card") status.
Leslie is the co-author of Canadian Companion to 1040 Preparation and Planning Guide, a CCH publication. She is a frequent speaker across Canada on U.S. tax law, especially in the cross-border context.
Leslie exclusively practices U.S. law and is admitted to practice in New York.
Silver & Co.
Monte Silver is the founding partner of Silver & Co. After working in U.S. Federal and state tax governmental agencies as well as the U.S. Tax court, he now focuses on representing clients on business and tax matters related to the United States. Having accumulated extensive experience in both U.S. taxation planning and litigation, Monte specialises in developing solutions for high wealth clients with regard to their U.S. matters.
Monte has spent half his life in North America and half in Israel. Residing in Israel, Monte frequently travels throughout Europe and the United States pursuing the legal interests of his clients. He is passionate about tax advocacy and fighting to help American small businesses gain exemption from the transition and GILTI taxes.
His government sector work includes:
Honorable Judge Larry Nameroff, United States Tax Court
Internal Revenue Service, Estate and Gift Tax Division, Boston MA
Brad Sherman, Chairman of the California State Board of Equalization (SBE). The SBE is in charge of the California tax system. (Mr. Sherman is currently a senior U.S. Congressman).
He is admitted to the Bar in the State of California and in Israel.
Pricing and booking
Book now for the best prices
Book early for reduced prices
For bookings up to 31 December 2019:
Members of the US Professionals Association: CAD$1400 plus 13% HST
Non-members: CAD$1800 plus 13% HST
For bookings from 1 January 2020:
Members of the US Professionals Association: CAD$1500 plus 13% HST
Non-members: CAD$1900 plus 13% HST
Prices include course documentation, lunch and unlimited refreshments throughout.
This year’s conference is hosted by “CPD programs”, to whom payments can be made by email transfer or credit card. Details will be shown on the invoice.
CE, CPD, CPE credits
A total of 12 credit hours will be available for this event.
150 King Street West
The venue for the conference is Vantage Venues, formerly the St. Andrew’s Club and Conference Centre, at 150 King Street West. Our conference room is on the 27th floor of the Sun Life Financial Tower.
It is located in the heart of Toronto, near all major hotels and connected through the underground path system to all major office towers in the city core as well as sitting atop the St. Andrews subway station.
Booking terms and cancellation policy