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Federated Press 16th Annual Taxation of Corporate Reorganization Seminar

The "16th Taxation of Corporate Reorganization" seminar will take place in Toronto, Ontario, Canada on 16 Jan 2012.

Metropolitan Hotel, Toronto ON, Canada

FMC Counsel Donald G.H. Bowman Q.C. will be speaking the Latest Tax-Avoidance and GAAR Developments at the Federated Press 16th Annual Taxation of Corporate Reorganization Seminar.

*Hear the latest developments affecting the taxation of mergers, takeovers, amalgamations and asset acquisitions
*Explore the latest developments and tax planning strategies for the 88(1)(d) bump on an amalgamation or wind-up
*Uncover strategies involving paid-up capital in the context of internal reorganizations*Review developments in Canadian and U.S. cross-border tax rules
*Examine the latest developments affecting the reorganization and taxation of foreign affiliates
*Get best practices for structuring a Canadian exchangeable share transaction
*Study the most current issues in tax avoidance and developments in GAAR
*Review share and asset acquisition tax attributes and the options available to minimize taxes
*Explore legislative changes, case law and changes in the CRA’s position regarding tax-loss use

Agenda
- Examination of the elements of the general anti-avoidance rule: have we achieved “consistency, predictability and fairness”?
- Key current GAAR cases: what is currently working its way through the GAAR pipeline?
- CRA’s positions on abusive transactions
- A review of recent non-GAAR tax avoidance cases
- The CRA’s “Aggressive Tax Planning Division”: what are they pursuing?

Participating Organizations:
*Borden Ladner Gervais LLP
*Couzin Taylor LLP/Ernst & Young LLP
*Davies LLP
*Davies Ward Phillips & Vineberg LLP
*Ernst & Young LLP
*Fasken Martineau DuMoulin LLP
*Fraser Milner Casgrain LLP
*Goodmans LLP
*Heenan Blaikie LLP
*Moskowitz & Meredith LLP/KPMG LLP
*Osler, Hoskin & Harcourt LLP
*Sullivan Cromwell LLP

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