Master key strategies in tax and M&A, from navigating complex regulations like GAR and trust reporting to optimizing deal structures and maximizing tax efficiencies in transactions.
This advanced course provides a deep dive into the evolving landscape of Canadian tax law, highlighting significant legislative updates, court interpretations, and practical challenges faced by tax practitioners. Led by experienced tax lawyers, this session unpacks key developments in areas such as the General Anti-Avoidance Rule (GAAR), mandatory reporting and notifiable transactions, trust reporting requirements, and capital gains planning.
The discussion explores how new legislative amendments and administrative interpretations are reshaping tax planning strategies. From economic substance tests and the fairness preamble under GAAR to expanded audit powers and new disclosure obligations, participants gain a clear understanding of both the compliance expectations and the professional judgment required in applying these complex rules.
Practical insights are shared on how to identify and document commercial purpose, manage penalty risks, and adapt to changes in enforcement trends. Real-world examples—including surplus stripping, intergenerational transfers, employee ownership trusts, and bare trust filing rules—provide participants with concrete tools to strengthen advisory practices, ensure compliance, and anticipate risk in today’s heightened enforcement environment.
Topics Covered
1. The Current Tax Environment
2. The General Anti-Avoidance Rule (GAAR)
3. Mandatory Disclosure and Reporting Rules
4. Trust Reporting and Bare Trusts
5. Capital Gains Planning After Legislative Changes
6. Emerging Opportunities and Transitional Rules
7. Practical Compliance and Risk Management
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.
Partner at Miller Thomson
Andrew’s practice covers a broad spectrum of taxation law, with a primary focus on private corporations, trusts, family groups, and individuals. Areas of focus include transactions and reorganizations, tax dispute resolution and litigation, trust and estate matters, First Nation taxation, and goods and services tax. As a sought-after speaker and writer, Andrew provides insights to respected associations and publications, such as the Canadian Tax Journal, Legal Education Society of Alberta, Canadian Bar Association, Banff CA Small Practitioners Forum, and the University of Calgary Faculty of Law. Before becoming a lawyer, Andrew earned his Bachelor of Commerce and spent 10 years in the franchising industry, where he worked in a number of sales and executive roles. This hands-on experience shaped Andrew’s aptitude for negotiations, strategy, problem-solving, and conflict management. Andrew obtained his Juris Doctor degree from the University of Calgary and received a number of tax and other academic awards. Prior to joining Miller Thomson, Andrew practiced for 15 years at a boutique tax law firm in Calgary.
Partner at Miller Thomson
Bryant Frydberg is an experienced corporate tax and mergers and acquisitions lawyer who works mainly with owner / manager and other private corporations. Bryant also carries on a complementary business law practice. Bryant is committed to providing excellent service. He is accessible and responsive; he takes a pragmatic approach to solving problems and helping clients achieve their goals and objectives. Bryant’s practice includes: Corporate tax law: Bryant advises on all matters of corporate tax law including mergers and acquisitions, succession planning, planning and implementing other corporate reorganizations, and tax-driven corporate restructurings for private corporations. Mergers and acquisitions: Bryant acts for both purchasers and sellers in Canadian and cross-border merger and acquisition transactions, including structuring of the purchase and sale transaction. Corporate/commercial law: Bryant assists with unanimous shareholder agreements, cost-share agreements, and general business law matters. Bryant has considerable experience in transactions with dental support organizations (DSO), including selling dental practices to DSOs and structuring of DSOs. Bryant is a frequent writer and speaker on tax and corporate/commercial matters. He is also the editor of the “Estate Freeze” chapter in Miller Thomson on Estate Planning.
