Agenda - November 6th, 2019


Welcome and Introduction by PBLI


Chair's Welcome and Introduction


Alexander Demner

Thorsteinssons LLP



Basics of Real Estate Taxation


Sam Liang

Liang Tax Lawyers


  • Development
  • Investment
  • Costs and related issues
  • Financing

      - Debt

      - Equity

      - Interest payments

  • Characterization: Income vs. capital



Questions and Discussion


Refreshment Adjournment


Structuring the Deal: Part I


Sindy Wong

Smythe LLP


Maggie Puhacz

Smythe LLP


  • Structuring alternatives: pros and cons
  • Non-resident considerations
  • Personal vs. commercial investments



Questions and Discussion


Structuring the Deal: Part II


Rebecca Cynader

Farris LLP


Ron Dueck

Farris LLP


  • Tax on Split Income (TOSI) and real estate investments
  • Taxation of passive investment income in private corporations
  • Partnership investments and stub period accrual rules
  • Acquisitions and "bump" planning



Questions and Discussion


Networking Lunch


Dispositions of Real Estate


Michelle Moriartey

Legacy Tax + Trust Lawyers


Laura Peach

Legacy Tax + Trust Lawyers


  • Contractual considerations before the deal is finalized
  • Non-resident dispositions: Section 116 certificates
  • Audits and assessments: Dealing with the CRA



Questions and Discussion


Refreshment Adjournment


Commodity Taxes and Property Transfers

Terry Barnett

Thorsteinssons LLP


Zheting Su

Thorsteinssons LLP


  • Good and services tax

      - Some basics: What is exempt and what is taxable?

      - Self-assessment versus payment to vendor

      - Recovery of GST paid: Don't take input tax credits for granted

      - Bare trusts and joint ventures: Registering the wrong person can cost you

      - Assignment of purchase contracts

  • Provincial sales tax

      - When are fixtures subject to PST?

      - PST and construction contracts

  • Property Transfer Tax



Questions and Discussion

   3:45 Provincial/Municipal Taxes

Alexander Demner

Thorsteinssons LLP


  • Speculation Tax
  • Foreign Buyers' Tax
  • Empty Homes Tax
  • Land Owner Transparency Act
  • School Tax


   4:35 Questions and Discussion
   4:45 Chair's Closing Remarks 
   4:50 Program Concludes