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Eastern Edition Advanced Course

ADVANCED CANADIAN MINING TAXATION

May 25, 2012 I St. Andrew's Club and Conference Centre I Toronto
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This new advanced course offers senior tax executives and professional advisors an in-depth review of a selection of mining tax issues.

Topics to be discussed include:

  • The concept of a "Canadian resource property"
  • The successor corporation rules
  • The use of partnerships, including the new income deferral rules
  • A case study of how a foreign entity can invest in a Canadian mining project
  • Structuring foreign operations
  • Recent trends in mergers and acquisitions
  • Recent issues in flow-through shares

CONFERENCE AGENDA


MAY 25, 2012
8:15

Registration and Continental Breakfast
9:00

Opening Remarks from the Course Leaders
9:15

What Is a Canadian Resource Property

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

Liam M. Fitzgerald 
Partner
PricewaterhouseCoopers LLP

  • Definition in s.66(15)
  • Difference between a loan, a resource property and a royalty
  • Streaming transactions: the typical structure
10:15

Networking Coffee Break
10:30

Successor Corporation Rules

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

  • Transfers of property
  • Amalgamations
  • Windings-up
  • Acquisition of control
  • Arrangements
  • Butterflies
11:30

Partnerships

Liam M. Fitzgerald 
Partner
PricewaterhouseCoopers LLP

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

John Gravelle 
Partner
PricewaterhouseCoopers LLP

  • Investment tax credits
  • LP versus general partnership: what's the difference?
  • Transfers to and rollover rules
  • CDE washes: use to unsuccessor resource pools
  • New deferral rules
  • Inbound investment case study:
    • comparison of a joint venture and a partnership
    • off take agreements and cash investment
12:30

Networking Luncheon
1:45

Structuring Foreign Operations

Liam M. Fitzgerald 
Partner
PricewaterhouseCoopers LLP

John Gravelle 
Partner
PricewaterhouseCoopers LLP

  • Branch: CFRE rules
  • Examples of some typical structures: Mexico, Africa and Columbia
2:45

Networking Refreshment Break
3:00

Recent Trends in Mergers and Acquisition Activity

Lawrence Teltscher 
Partner
KPMG LLP

  • Triangular amalgamations
  • Breaking s.85.1:
    • trend to add a penny to typical share-for-share exchange
    • secondary amalgamation: bump and run versus PUC
  • PFIC rules in the junior sector
  • Convertible debentures
  • Spin-outs
  • Butterflies
4:00

Flow-Through Shares

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

  • Agreements in public offerings
  • Prescribed shares and rights
  • The look-back rule
  • Back-to-back arrangements
5:00

Course Ends
 

CLE Accreditation

This program qualifies for 6 substantive hours and can be applied towards the 9 of the 12 hours of annual Continuing Professional Development (CPD) required by the Law Society of Upper Canada.

WHO SHOULD ATTEND

  • 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 tax issues facing their industry so they can, among other things properly estimate the economic returns from their company's mining project. This advanced course has been newly developed to address the more complex mining industry tax issues as well as offering an update of the current tax issues facing the industry. Please note that attendees should have an understanding of the fundamentals of the mining tax rules in order to maximize their benefit from this course.

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 Insight Information and the distinguished members of our course faculty, we look forward to welcoming you to this new course on CANADIAN MINING TAXATION. Revised based on past attendees demand – continuing a tradition of excellence, we are very pleased to present this course in Toronto.

MEDIA PARTNER
COMPANY NAME

HOTEL RESERVATIONS

The St. Andrew's Club and Conference Centre is conveniently located at 150 King Street West, Toronto, Ontario. Tel. 416-366-4228. For overnight accommodation, please call The Hilton Toronto, located at 145 Richmond St. West, Toronto, Ontario. Tel. 416-869-3456. Please ask for the Insight Information corporate rate # N9920015 (subject to availability).

PRICE

Registration Fee: (Includes meals, documentation and inCONFERENCE™, fully searchable online access to this conference's papers*)

Description Price Tax Total
Course Price $1,395.00 HST (181.35) $1,576.35

I would like to order an extra copy of the conference binder (1 conference binder is included in the registration fee) $100.00 +  13% HST

* Please allow 2 weeks after conference for activation of login and password.

CANCELLATION AND REFUND POLICY

A refund (less an administration fee of $200 plus HST) will be made if notice of cancellation is received in writing three weeks before the event. We regret that no refund will be given after this period. A substitute delegate is welcome at any time.

SPECIAL OFFER: Send 4 people for the price of 3!

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.

INSIGHT INFORMATION REWARD PROGRAM:

Attend multiple Insight Information conferences in 2012 and/or register during 2012 and save! Attend and/or register for a 2nd conference in the calendar year (January to December) and receive a 25% discount and attend and/or register for a 3rd conference and receive a 50% discount. Buy more and save!

PRIVACY POLICY:

PRIVACY POLICY:By registering for this conference, Insight Information will send you further information relating to this event. In addition, you may receive by mail, telephone, facsimile or e-mail information regarding other relevant products and services from either Insight Information OR third parties with whom we partner. If you do not wish to receive such information from either Insight or third parties, please inform us by email at privacy@alm.com or by telephone at 1 888 777-1707.

Please note: Full payment is required in advance of conference dates. Please make all cheques payable to Insight Information.

INSIGHT INFORMATION reserves the right to change program date, meeting place or content without further notice and assumes no liability for these changes.