Agenda - March 10th, 2021


Welcome and Introduction by PBLI


Chair's Welcome and Introduction


Asif Abdulla

Thorsteinssons LLP



Case Law Update


Jacqueline Fehr



  • A review of recent decisions about tax disputes and appeals



Questions and Discussion


Morning Break


Audit Management 101


Michelle Moriartey

Legacy Tax + Trust Lawyers


  • Understanding CRA's audit powers and the limits of what CRA can demand
  • Requirements to Provide Information (both domestic and foreign-based information)
  • Exchange of information under tax treaties
  • Risk assessment and mitigation strategies



Questions and Discussion


Representation and Appeals


David Jacyk

Osler, Hoskin & Harcourt LLP


  • Tax objections
  • Navigating the appeals process
  • Settlements



Questions and Discussion


Lunch Break


CRA Special Projects


Robert Carvalho

Thorsteinssons LLP


  • The Related Party initiative
  • The Postal Code project
  • Other special projects



Questions and Discussion


Afternoon Break


Criminal Investigations


Jennifer Flood

Thorsteinssons LLP


  • The CRA's powers to investigate criminal tax evasion
  • How an audit can lead to a criminal investigation and prosecution
  • Protecting advisor and client interests in high-risk situations



Questions and Discussion


A View from the Bench

The Honourable Eugene P. Rossiter

Tax Court of Canda


  • A judge's perspective on the work of the Tax Court of Canada


   4:15 Questions and Discussion
   4:25 Chair's Closing Remarks
   4:30 Forum Concludes