Webcast Details

Handout Materials

Presentation Slides Bio of Anne Calverley Bio of Don Sommerfeldt Bio of Christopher Steeves Bio of Thomas P. Bishop Webcast Evaluation Transcript

Presented by ACC's Energy Committee, sponsored by Fraser Milner Casgrain LLP 

In 2007, there were significant changes in both Canadian tax law and the Canada-United States Tax Treaty that will affect international tax planning. Virtually all organizations, including energy companies, with fiscally transparent entities such as US LLCs, Canadian ULCs, or partnerships within their corporate structure will be affected by these changes when making cross border payments of interest, dividends and royalties. With Canada's Department of Finance presently unwilling to provide relief for unintended adverse tax consequences that will be realized by many organizations, now is the time to review possible restructuring solutions.

This webcast will examine changes to the Canada-US Tax Treaty that will affect withholding tax rates on certain cross border payments. The presenters will provide insight on possible restructuring solutions and discuss changes to Canada's Income Tax Act.

Anne Calverley is a partner in the Calgary office of Fraser Milner Casgrain LLP. Anne practices law exclusively in taxation and manages tax planning for resource based corporations. Anne taught advanced resource taxation for 10 years and participated in the publication of "Canadian Resource Taxation" as a co-author.

Don R. Sommerfeldt is a consultant of the Edmonton office of Fraser Milner Casgrain LLP. Don practices reorganizations, tax planning, estate planning, wealth management. Previously, Don worked at the Department of National Revenue, where he drafted advance tax rulings and technical interpretations.

Christopher J. Steeves is a partner in the Toronto office of Fraser Milner Casgrain LLP. Christopher practices tax law regarding various issues of domestic and cross-border financings. Christopher was ranked as one of Canada's leading tax lawyers in the 2006 Chambers Global Guide and was recommended by the Practical Law Company.

Moderator:  

Thomas P. Bishop, Vice President & Associate General Counsel, Southern Company