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Fixing Tax Mistakes - Rectification

Tax Breakfast Seminar Series (Fasken Martineau Institute)
When
Where Fasken Martineau
333 Bay Street, Suite 2400
Bay Adelaide Centre
,
Toronto, ON
M5H 2T6
Canada
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Fasken Martineau Tax Breakfast Seminar Series

Rectification is an equitable remedy which may be granted by courts to restore taxpayers to a position in respect of completed transactions that accords with the taxpayers’ original intentions. Rectification may, in effect, retroactively correct completed transactions such that the tax outcomes of the transactions reflect those which the taxpayers intended. Since the Juliar decision, tax advisors have become increasingly aware of the role that rectification can play in assisting parties to avoid unintended and, potentially, enormously disadvantageous tax results of transactions. Where successful, rectification applications may not only serve a taxpayer’s interest, but also assist the taxpayer’s advisors in minimizing the likelihood of negligence claims, or at least, mitigating losses associated with potential errors made by advisors in tax planning and implementation advice provided to the client.

However, rectification is not a “cure all” which will automatically be granted by courts in every circumstance in which the outcomes of tax planning and/or transactions are not exactly as advised or contemplated.

This seminar will provide those in attendance with:

  • the most recent guidance in respect of rectification;
  • the circumstances in which this remedy may be available;
  • practical advice regarding addressing rectification with clients;
  • advice regarding the process of preparing effective rectification applications;
  • guidance with respect to avoiding the inadvertent waiver of solicitor and client privilege associated with transactions requiring rectification;
  • information regarding the role of the Canada Revenue Agency in the rectification process; and
  • guidance regarding the litigation and advocacy components of the in-court rectification process.

Fixing Tax Mistakes – Rectification is another installment in the Fasken Martineau Tax Breakfast Seminar Series offered to taxpayers and tax and estates advisors by David Fox, a partner in Fasken Martineau’s Tax Group. In this seminar, David will be joined by a panel including Paul Monahan and Christopher Steeves, senior partners in the firm’s Litigation and Tax Groups, respectively.

Agenda

  • 8:00 am - 8:30 am Registration & Breakfast
  • 8:30 am - 10:00 am Program

Note: The hours from this non-accredited seminar may be applied towards the 9 Substantive Hours of annual Continuing Professional Development (CPD) required by the Law Society of Upper Canada for Ongoing Members. Please note that this seminar is not accredited for Professionalism Hours and cannot be counted for New Members or for Professionalism Hours for Ongoing Members.

Type

This is an in-person seminar.

Cost

This seminar is complimentary.

RSVP

Please RSVP by March 12, 2014 by clicking the link in the top right of this page.

For more information:

Zahra Malik
+1 416 868 3329
zmalik@fasken.com