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‘Building a Global Future’

Moore Global’s Real Estate & Construction Summit Series ‘Building A Global Future ‘

July 14, 2021 — July 15, 2021
9:00 AM-12:00 PM (EST)

Moore Global is pleased to present the Moore Real Estate and Construction Summit Series, “Building a Global Future”. A collection of thought leadership pieces addressing issues and opportunities within the real estate landscape on a global scale. We hope you join us as we explore these timely topics, including investment flows, tokenization of real estate assets, unleashing crowdfunding potential, and learning from distinguished women within the real estate realm.

This is an exclusive event in the real estate and construction sector, with the purpose of connecting and communicating with businesses beyond boundaries.

Agenda

Below are the scheduled sessions. Please follow the link HERE to register for the sessions you’d like to attend and add to your calendar.

July 14, 2021

Tokenization of Real Estate Assets 9:00 AM-9:30 AM ET

Women in Real Estate and Construction 10:00 AM-10:30 AM ET

Crowd Funding 11:00 AM-11:20 AM ET

July 15, 2021

Global Real Estate Investments Trends and Opportunities 9:00 AM-10:00 AM ET

Moore Global’s Real Estate Resource Portal 10:00 AM-10:05 AM ET

Constructing the New Normal 11:00 AM-11:30 AM ET

To register and learn more about the event, please CLICK HERE.

M&A Deal

Segal LLP’s Valuation and Transaction Advisory services team acted as exclusive financial advisor on the sale of M&E Engineering Ltd. Learn more about the deal announcement HERE.

Moore Global Appoints Dan Natale as New Global Leader

Moore Global, one of the world’s leading accountancy and advisory networks, has today announced five of its sector leaders have been appointed Global Leaders. As part of this group, Dan Natale, Managing Partner of member firm Segal LLP, has been appointed Global Leader, Real Estate and Construction.

These newly created roles support Moore Global’s continued growth strategy and emphasise the business’s plans to strengthen its global leadership position in key sectors around the world.

In addition to Mr. Natale, forming the new team of five Global Leaders are;

  • Mr. David Tomasi, Managing Partner, Moore Australia (WA) – Global Leader, Energy, Mining, and Renewables
  • Mr. Graham Tyler, Partner, Moore Kingston Smith – Global Leader, Media
  • Mr. Mark Fagan, Partner, Citrin Cooperman & Company LLP- Global Leader, Manufacturing and Distribution
  • Mr. Costas Constantinou, Managing Partner, Moore Greece – Global Leader, Maritime

As principal experts, Mr. Natale and the other Global Leaders will work alongside the 600 plus industry group members and be responsible for promoting and positioning the sectors within the market, driving sector growth and supporting collaboration within the network.

Commenting on the announcement, Anton Colella, Global CEO, Moore Global, said: 

“At the heart of our strategy, we aim to be the world’s most respected professional services network and to drive that business strategy forward and lead our global community, we need an exceptional leadership team.

Dan has already proven his dedication to supporting our business growth and I’m confident that within his new role, he will continue to shape our business, helping our clients and the wider Moore Global team tackle the key challenges of modern business, and ultimately help them thrive.”

Commenting on his new role, Dan Natale, said: 

“I am excited to head Moore Global’s Real Estate and Construction team and look forward to continuing our network’s outstanding leadership in this sector. Together, we will apply our extensive knowledge and experience within the real estate industry, as well as leverage our relationships in the sector, to further expand the influence, capability and reach of our combined service offering. As a leader, I am dedicated to ensuring our network provides the highest-calibre advice and resources to our valued clients. The industry is continuously evolving and as such, collectively we intend to steer our clients into the future with the confidence and insights needed to succeed both locally and globally.”

Please read the full announcement HERE.

2021 Federal Budget Commentary

On April 19, 2021, the Canadian government released the federal budget for 2021.

This budget may be better known for what is not in it versus what is in it. Our focus is on the tax changes. We will leave the spending and program discussions to the political pundits.

There was significant discussion before the budget about capital gains changes. We can confirm that there were no changes to the following:

  • Capital Gains Tax Rates
  • Principal Residence Exemption taxation
  • Taxation of Non CCPC companies
  • Taxation of Professional Corporations

Please follow the link below to our summary comments of the budget and a more detailed listing of the budget highlights. 

Segal Summary and Budget Highlights

If you have any questions, please do not hesitate to contact your Segal tax advisor.

Cameco Corporation – Supreme Court of Canada rejects hearing the CRA’s Application for Leave Appeal

In Canada’s landmark transfer pricing case, the Supreme Court of Canada rejected hearing the Canada Revenue Agency’s Application for Leave to Appeal against Cameco Corporation

On February 18, 2021, Canada’s highest court rejected the Canada Revenue Agency’s (CRA’s) application for Leave in the case of Cameco Corporation. The Supreme Court only hears a select number of cases each year based on it being of significant public importance or if it raises an important issue of law or both law and fact. Furthermore, the Supreme Court does not provide reasons for dismissing or granting a leave application. That said, the Supreme Court of Canada’s decision to reject the CRA’s application is being viewed as that it stands by the previous interpretations and application of the recharacterization provisions in Section 247 of the Income Tax Act, made by the Federal Court of Appeal and the Tax Court of Canada.

One can conclude that the Crown’s arguments did not influence the Supreme Court of Canada’s decisions in considering the appeal of significant pubic importance, partly based on the quantum of transfer pricing assessments issued by the CRA over the past three years. As one of its grounds of appeal, the CRA estimated that the outcome would have made adjustments to Cameco Corporation’s taxable income to the extent of $11.84 billion.

The Federal Court of Appeal previously dealt with the interpretation and application of paragraphs 247(2)(b) and (d) of the Income Tax Act, which pertains explicitly to recharacterization. The recharacterization provision is only applied when the intercompany transactions would not have been entered into by independent third parties (i.e., parties dealing at arm’s length). The premise is that such transactions were not entered into except for good faith and not for tax planning purposes or gaining a tax benefit. The Crown had argued that the recharacterization provisions were applicable considering the taxpayer’s specific circumstances, which the Federal Court of Appeal rejected. The Federal Court of Appeal instead interpreted that the recharacterization provision specifically applied if the transactions were not entered into by independent third parties (i.e., parties dealing at arm’s length), which could not be validated based on the Crown’s arguments.

In rejecting the CRA’s Application for Leave Appeal, the Supreme Court of Canada has provided certainty and relief to taxpayers on interpreting and applying the recharacterization provisions in the Income Tax Act.

Based on recent trends in the Government’s approach to assessing intercompany arrangements, corporate taxpayers must prepare themselves to defend their transfer pricing positions. Contact our Principal & Transfer Pricing Leader Avinash S. Tukrel for more information on how our team can help you develop a framework suited to your Multinational Group’s unique needs in an ever-evolving international tax and transfer pricing environment.