Foreign Affiliates 2014

Highlights:

• Hear the latest proposed technical changes to Foreign Affiliate rules as well as recent Comfort Letters issued by the Federal Department of Finance

• Get an update of the latest issues and trends related to foreign affiliate taxation, along with a glimpse into what to expect in the future

• Explore basic concepts underpinning the foreign affiliate regime

• Look at the most recent and interesting tax treaty issues in the context of foreign affiliates

• Review the issues associated with the FAPI rules

• Get an overview of alternatives for structuring foreign affiliates to minimize taxes • payable on a global basis by Canadian-based multinationals

• Take a detailed and critical look at the latest developments surrounding tax-effective • financing opportunities with respect to foreign affiliates

Participants:

• Couzin Taylor LLP / Ernst & Young LLP

• Deloitte LLP

• Dentons Canada LLP

• KPMG LLP

• Osler, Hoskin & Harcourt LLP

• PricewaterhouseCoopers LLP

Registration:

To reserve your place, call Federated Press toll-free at 1-800-363-0722.

In Toronto, call (416) 665-6868 or fax to (416) 665-7733. Then mail your payment along with the registration form. Places are limited. Your reservation will be confirmed before the course.