FUNDAMENTALS OF
CANADIAN MINING TAXATION

This course offers a solid educational foundation or refresher for financial executives, government officials and professional advisors in the mining industry.

Topics to be discussed include:

• Foreign investment considerations in Canadian mining: analyzing cross border, inter-company financing issues
• Mining investment tax credits for companies and investors
• Utilizing flow-through shares to deduct 2011 expenses in 2010
• Strategies for structuring and financing foreign and domestic resource ventures
• Gaining access to beneficial tax treaties

COURSE FACULTY

Brian R. Carr
Partner, Moskowitz & Meredith LLP/KPMG LLP

Garry Eng
Partner, PricewaterhouseCoopers LLP

Susan McKilligan
PricewaterhouseCoopers LLP

Scott Jeffery, CA
Partner, KPMG LLP

This conference has been approved by the Law Society of British Columbia
for 6 hours.

This program has been approved by the Law Society of Saskatchewan for 6 hours and
for 1 Loss Prevention Credit for the outgoing Loss Prevention Credit Program.

MARKETING PARTNERS

MEDIA PARTNER

• Mining Industry Professionals
  • Controllers
  • CFOs, VPs of Finance and Treasury
  • Managers of Taxation
  • Directors/Managers Corporate Development
• Corporate Tax Accountants
• Auditors
• Lawyers
• Consulting Engineers

• Bankers
• Investment Counsel
• Brokers
• Financial Professionals
• Regulators
• Resource Economists
• Policy Advisors
• Federal and Provincial Government Officials
• First Nations Mining Regulatory Officials and Businesses

Mining professionals need a solid understanding of the fundamental tax treatment of their industry to plan their company projects effectively.

Since it was first offered more than twenty years ago, hundreds of mining industry professionals have used this comprehensive course as a reliable, fast and economical way to bring themselves up to speed on the key tax issues affecting exploration and development within the Canadian mining industry.

Highlights of this year’s course include issues for the foreign investor to consider when looking at Canadian mining companies including cross border, inter-company financing and exit strategies.

Take this opportunity to get the essential grounding you need from a faculty of knowledgeable experts highly skilled at effectively communicating mining tax concepts.

On behalf of Insight Information and the distinguished members of our course faculty, we look forward to welcoming you to the FUNDAMENTALS OF CANADIAN MINING TAXATION course.

FRIDAY, MAY 7, 2010

8:00

Registration and Coffee

8:55

Welcoming Remarks from Insight Information

9:00

Opening Remarks from Course Leaders

9:15

Exploration and Development: Tax Planning Considerations

• Canadian Exploration Expenses (CEE)
• Canadian Development Expenses (CDE)
• Pre-production tax credits
• Successor corporation rules

Maximizing the Capital Cost Allowance (CCA)

• Fixed asset vs. CDE/CEE
• Typical CCA classes for mining assets
• CCA for pollution prevention equipment
• Accelerated Capital Cost Allowance
  • quick write-offs for new mines and major mine additions
  • basic and expanded criteria

10:30

Networking Coffee Break

10:45

Structuring Domestic Resource Ventures

• Joint ventures and partnerships
• Royalty arrangements and trust arrangements
• Farm-ins
• Tax implications of royalty carve-outs

Inbound Transactions: Non-Resident Investment in Canada

• Inter-company Financing
  • thin capitalization
  • withholding tax
  • interest deductibility and general deductibility limitations
  • foreign taxation of shareholders
  • increasing equity base
• Distributions from Canada
  • dividends
  • return of capital
  • investment in foreign subsidiaries
• Structuring an acquisition
• Exit Strategies
  • taxation of capital gains
  • taxable Canadian property
  • treaty protection
  • pre-sale dividends
• Treaty Shopping
  • migrating existing structures
  • GAAR

12:00

Networking Luncheon

1:15

Federal Tax Changes to the Resource Sector

• Tax rate reduction schedule
• Deduction for mining taxes and Crown royalties
• Proposed limitations on losses
• Assessing the impact on a typical mining company

Analyzing Flow-Through Shares

• Definition of a flow-through share
• Analysis of the rules
  • transferring CEE and CDE deductions to investors
  • limits on the forms of expenses that can be renounced
• Prescribed shares
• Compliance
• Holding flow-through shares in a limited partnership
• Advantages and disadvantages of flow-through shares
• The One Year Look-Back Rule - how 2011 expenses can be deducted in 2010
• Discussion of Canadian Renewable and Conservation Expense
• Mining “super-ITC” for individuals

Provincial/Territorial Mining Taxes: An Update

• Purpose and basic structure
• Federal tax treatment
• Selected examples of provincial regimes
• Cross-country round-up of provincial developments

3:00

Refreshment Break

3:15

Structuring and Financing Foreign Resource Ventures

• Active Business Earnings
  • exempt surplus and taxable surplus
  • underlying foreign tax
• FAPI
  • income from property
  • deemed active business income and deemed FAPI
  • hedging
  • sale of resource properties
  • capital gains
• Offshore Holding Companies
• Financing Foreign Operations, Acquisitions, Divestitures and Reorganizations

4:00

Acquisitions, Divestitures and Reorganizations

• Acquisition considerations
  • Assets vs. shares
  • Acquisition of control and successor rules
  • Recent acquisitions of interest
  • Section 85 vs. Section 85.1
  • Due diligence considerations
  • Deductibility of interest and financing charges
  • Treatment of acquisition costs
  • Break up fees
• Reorganizations and divestitures
  • Amalgamations, wind-ups and other transfers of resource property
  • Spin-out transactions
• Debt forgiveness rules

5:00

Course Ends

Register 3 delegates for the main conference at regular price at the same time and you’re entitled to register a fourth person from your organization at no charge. For other group discounts, please call 1-888-777-1707. All discounts must be redeemed when booking, discounts will not be valid or applied after this time.