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Intellectual Property Migration: How Tax Authorities Plan to Crack Down on Profit Shifting Initiativ
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Toronto Chapter Meeting

When: Thursday, February 26, 2015
6:00 PM - 8:00 PM
Where: The Office Pub
117 John St
Toronto, Ontario  M5H 1Y2

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Toronto Chapter Meeting

Thursday, February 26, 2015
6:00 PM - 8:00 PM

Quinn’s at the Sheraton Centre
96 Richmond Street West
South Board Room

Intellectual Property Migration: How Tax Authorities Plan to Crack Down on Profit Shifting Initiatives

Michelle Levac, CA, CPA, CBV, CFA, Chair of Working Party No. 6, dealing with the taxation of Multinational Enterprises, at the Organization for Economic Co-operation and Development (OECD)

As private companies expand into foreign markets, the use and transfer of intellectual property between related companies to different jurisdictions can achieve a number of business objectives, and can increase a company’s future profitability by reducing the income taxes paid by the combined organization. But, some of these strategies may actually reduce after tax profits and put the company in the middle of a tug-of-war over international tax issues, and potentially causing the organization to incur excess income taxes, interest and even penalties. For organizations looking to expand their operations into foreign jurisdictions, move their IP to subsidiaries in a different country, or for advisors who assist their clients with these strategies, being aware of the risks is important to avoiding unintended consequences. The Canada Revenue Agency and other tax authorities through the Centre for Tax Policy and Administration at the Organization for Economic Co-operation and Development (OECD) have embarked on a Base Erosion and Profit Shifting program that includes a series of initiatives aimed at giving countries the tools they need to ensure that profits are taxed where economic activities generating the profits are performed and where value is created, while at the same time giving business greater certainty by reducing disputes over the application of international tax rules, and standardizing requirements.

This presentation provides business owners, IP professionals, lawyers, accountants and valuation specialists with a unique front-line opportunity to hear about how the OECD’s initiatives and the current environment amongst governments and tax authorities might affect you or your client’s plans to move intellectual property to different jurisdictions.

LES Member: $25
Non-Member: $30
Includes hors d’oeuvres

Please confirm your attendance, as we need this information to order food and chairs.

The LES Toronto Chapter now uses online registration and all LES members and non-members may register online using their LES online account.

  1. Register online and pay by credit card (USD); or
  2. Register online and pay by check (CAD)
    Make check payable to "Licensing Executives Society"

Online Registration Deadline: Tuesday, February 24, 2015
Onsite Registration Available

Tuesday, February 24, 2015
Substitutions permitted

Michelle Levac is a Chartered Accountant, Chartered Business Valuator and Chartered Financial Analyst. She is Chair of Working Party No. 6, dealing with the taxation of Multinational Enterprises, at the Organization for Economic Co-operation and Development (OECD), is a Transfer Pricing Specialist at the Canada Revenue Agency and a Director on the Board of Directors of the Canadian Institute of Chartered Business Valuators. Michelle has 20 years of experience in business equity valuation and transfer pricing, including testifying as an expert witness, negotiating transfer pricing cases with foreign tax authorities, developing international transfer pricing guidance and frequently speaking at international tax events.


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