International Fiscal Association Canada 1Canada-Flag-Maple-Leaf

2015 President's Message: Welcome 2016 New Year

As Stephen Bowman has reached the end of his term as IFA Canada President, and Ron Durand has stepped up to fill that role for the next two years, we thought we would together provide a report on the year past and what lies ahead.

The Was's

2015 was a year of international tax activity, once again.  We held a very successful traveling conference in conjunction with the Canadian Tax Foundation in February, with appearances in both Toronto and Calgary.  As in 2014, we had excellent attendance and the benefit of a broad range of insights and exchanges from the presenters.

In May our traditional International Tax Conference was held in Calgary and we were delighted to welcome virtually the entire Alberta membership of IFA, in an unprecedented level of support that was great to see.  There is no doubt that the importance of international tax is not lost on our colleagues in Alberta and we look forward to being back in Calgary in the future.

In the course of the Alberta conference we had the pleasure of honoring another longstanding, in fact our most longstanding, IFA member, Mr. Arnold Sherman who is also now our newest honorary member.  Arnold has been a stalwart supporter of IFA for many decades and in his own professional life has made an important contribution to Canadian international tax practice and policy.  We are honored by his membership and delighted to recognize his contribution.

In Calgary we also had the pleasure of welcoming back a well-known Calgary tax practitioner, whom we now address as the Honourable Blair Nixon.  Justice Nixon now serves on the Alberta Court of Queen's Bench, but is better known to tax practitioners as a former tax lawyer and accountant.  His insights were insightful and eloquent.

In early September many of our members had the pleasure of attending the annual Congress in Basel.  It ran with predictable Swiss precision and the Canadian participation was outstanding.  We were once again fortunate to have many IFA Canada members involved in the program and we are grateful for the continuing efforts of Brian Schneiderman on the Executive Committee of IFA, Scott Wilkie as Vice-Chair of the Permanent Scientific Committee and Michael Kandev as the Young IFA Network delegate to the PSC - our Canadian participation in the global IFA organization has been outstanding and is a credit to the dedication of our members, and these three in particular! 

2015 was also a year in which the profound contribution of Brian Arnold to the international tax community was recognized by his friends and colleagues in Canada and from around the world. Following the CTF annual conference in Montreal, there was a gathering of tax practitioners, academics and government officials from across Canada and around the world to celebrate Brian's contribution to tax and in particular to international tax, through a conference, a dinner and a lively interaction of friends and colleagues who gathered to celebrate.  At the dinner in Brian's honour, both of us, along with Scott Wilkie, were delighted to be able to say a few words of thanks to Brian (albeit embedded in some humour) for his contributions to international tax and to IFA. We know that Brian will have returned to his farm outside London, Ontario warmed by the good wishes of his friends from around the world, and re-energized in his continuing pursuit of sound tax principles and policies.  The occasion was a celebration of Brian, but the celebrants were all members of the broader tax community in Canada and abroad who collectively support and pursue those same goals.

As only one small example of his many contributions to the tax community, Brian, together with Hugh Ault from Boston College, coordinated the recently published “United Nations Handbook on Selected Issues in Protecting the Tax Base of Developing Countries”.  This book contains many new and informative approaches to the analysis of base erosion and profit shifting including an overview by Brian and Hugh, as well as Brian’s chapter on the Taxation of Technical Services.  Wei Cui from UBC and Jinyan Li from Osgoode also wrote chapters, so that 3 ½ of the 10 chapters were written by Canadians!  IFA Canada and the Canadian Tax Foundation are proud to be the only independent sponsors of this book and we highly recommend it to anyone looking for insight into the real issues.

At our November Council meeting we moved through the traditional biennial change in leadership.  Our Past President, Nick Pantaleo, stepped down from our Executive and from Council.  Nick has made an outstanding contribution to IFA in Canada and internationally over the course of his career, and no one knows that better than the authors of this report.  Thank you, Nick, for all your work here and internationally.

We were also fortunate that we have once again been able to enhance our Executive with the recruitment of a new officer, Claire Kennedy, who joins the Executive as Secretary.  Lynn Moen (who joined the Executive in May) has moved to the position of Treasurer, Patrick Marley to Second Vice President, Brian Mustard to First Vice President and Ron Durand to President.  Stephen Bowman has joined the ranks of Past Presidents.  We thank all of the members of the Executive who have served for the last two years and we welcome Claire to the team as we move forward into the future.

Finally, we have decided to change the administrative support for the Branch from Events & Management Plus Inc. to the Canadian Tax Foundation.  Those who have worked closely with the Executive or who have been regular attendees at IFA events will certainly know Elizabeth Hooper, Heather Dow and their team.  They have helped us through a period of dramatic growth and maturation, from an organization that operated from the corner of someone's desk to an organization of well over 600 members with an annual agenda that organizes a range of events, publications and webinars.  Elizabeth has shepherded us through decades of meetings and conferences and is largely responsible for our growth into the organization that we are today.  Thank you Elizabeth.

The Will Be's

As we looked ahead, the Executive recognized that our ongoing programs and efforts ran in parallel with those of the Canadian Tax Foundation.  The CTF is of course the largest tax organization in Canada and a force in the tax world that has no parallel in most other countries. Our memberships overlap, our programs sometimes overlap (and sometimes compete) but our fundamental objectives are aligned - the fostering of thoughtful exploration of tax issues, the education of the tax community and the provision of an environment where tax practitioners can meet, interact and build professional relationships.  But there are significant differences, too.  IFA's mandate is entirely international; the CTF focuses on Canada.  We believe that the willingness and ability of the CTF to provide administrative support will allow us to better coordinate and manage IFA's agenda.

A change of this kind is unsettling.  IFA has always been independent of other organizations and under that model it has thrived here in Canada and as part of IFA internationally.  We have been asked whether IFA's independence is now in jeopardy.  The answer to that is no.  Our Council, our membership and our Executive remain dedicated to the objectives of IFA as enshrined in our by-laws and charter, and Larry Chapman and his colleagues at the CTF recognize and indeed support this reality.  We look forward to working with the CTF on the administrative level and, again, we express our deepest gratitude to Elizabeth Hooper, Heather Dow and their team at Events & Management Plus Inc.

We are excited about 2016. On February 9 in Toronto and two days later in Calgary we will run a joint conference with the Canadian Tax Foundation on “International Tax Planning for Canadians in a World of Changing Rules”.  The final details are still being ironed out but we anticipate speakers from Australia, Ireland, Luxembourg, The Netherlands, Switzerland, the United Nations and the United States.  Please join us for an informative, practical one day look at how to adapt to the changing tax world around us.

On May 26 and 27 we will hold our annual seminar at the Mount Royal Centre in Montreal.  This will be an opportunity to examine international changes in the first Liberal budget in a decade and to gain insight into Canada’s official reaction to many of the BEPS initiatives.

Michael Kandev has become one of the old folks and we are pleased to welcome Kim Maguire as the new president of the Young IFA Network.  We look forward to working with Kim and her committee to provide programs of particular relevance for young international practitioners.  We encourage you to watch for announcements of webinars and video conferencing programs in the coming year, as we explore new technologies for staying in touch and disseminating timely information on international tax developments to our members.

We plan to return to our traditional travelling lectureship format with stops in Montreal, Ottawa, Toronto, Calgary and Vancouver.  Given the lead time required for what is an enormous amount of work by the presenters, we are currently targeting late January or early February 2017 for the next sessions.

Last, but never least, is the annual international congress from September 25 – 30, 2016 in Madrid, Spain.  The main topics are dispute resolution procedures in international tax matters and the notion of tax and the elimination of international double taxation.  Seminars are expected to include recent developments in international taxation, how BEPS has affected the relocation of multi-national enterprises, the taxation of venture capital and other topical issues.  We look forward to seeing a large Canadian contingent in Madrid.

We wish you all happy holidays and a prosperous 2016.