EDUCATION/PROFESSIONAL DESIGNATIONS
B.A.-University of Texas at Austin, June 1967
Graduated as a Chartered Accountant-Institute of Chartered Accountants of Ontario, 1972.
Awarded Trust and Estate Practitioner designations from Society of Trust and Estate Practitioners, 1999
Chartered Professional Accountant (Ontario)-2012
PROFESSIONAL EXPERIENCE
May 1991-Present-Independent tax consultant on wide variety of tax issues (e.g. general corporate and business tax, corporate reorganizations, mergers and acquisitions, inbound and outbound international tax, estate planning, real estate, trusts, etc.). Mainly consulting to accounting firms; to a lesser extent consulting to legal firms and corporations.
August 1972-April 1991-In charge of tax group at Soberman Isenbaum & Colomby, Chartered Accountants, Toronto (admitted to partnership May 1974). This firm (now named Soberman LLP) is one of the 20 largest accounting firms in Canada.
BOOKS, PAPERS, ARTICLES, SPEAKING ENGAGEMENTS, ETC.
Canadian Taxation of Non-Residents (CCH Canadian Ltd.)- Soft covered book, originally published in 1995-2nd edition published in 2002; 3rd edition published in 2009; 4th edition published in March 2011. 5th Edition was published in July 2016. To order this book, press here
Canadian Taxation of Real Estate (CCH Canadian Ltd.)-Soft covered book, originally published in 1987, subsequent editions published in 1989 and 1992. 4th edition (co-authored by Ian MacInnis) was published in 2004.
Taxation of Real Estate in Canada (Carswell/DeBoo)-Hard covered book in loose-leaf format, originally published in 1989. Subsequent updates authored by Michael Atlas until 1995.
Advanced Real Estate Taxation course adopted in 1991 by Canadian Real Estate Association as part of its “CCIM” designation program.
“Post-Mortem Planning-Shares in Private Corporations”-STEP Toronto Branch-February 17, 2016
Webinar “Residency-The Most Fundamental Concept in Canadian Tax Law”-CCH Canadian-December 3, 2016
“A Review of the Residence Rules For Individuals, Trusts and Corporations” 2013 Ontario Tax Conference, Canadian Tax Foundation, October 29, 2013
Audioseminar “U.S.-Canada Cross-Border Tax Planning For Closely Held Businesses”, CCH Incorporated, September 3, 2013
Audioseminar “U.S.-Canada Cross-Border Tax Planning For Closely Held Businesses”, CCH Incorporated, June 6, 2012
Audioseminar “U.S.-Canada Cross-Border Tax Planning For Closely Held Businesses”, CCH Incorporated, March 24, 2011,
“Offshore Tax Planning-There is Still A Lot Left!”-Webinar presented on behalf of CCH Canadian Limited, December 14, 2010
“Current Income Tax Issues In Estate Administration”, 13th Annual Estate and Trusts Summit, Law Society of Upper Canada, November 17, 2010.
“Recent Tax Issues Relating To Investment in Canadian Real Estate by Canadian Residents”, 2010 Ontario Tax Conference, Canadian Tax Foundation
Audioseminar “Canada-U.S. Cross-Border Issues and Strategies”, CCH Incorporated, March 2, 2010.
Presentation entitled “Computing Income from a FIE”, as part of 10th Canadian National Conference of Society of Trust and Estate Practitioners, June 05, 2008.
Presentations entitled “Tax Issues for Non-Resident Investors in Canadian Real Estate”, as part of “Creative Tax Planning For Real Estate Transactions”, Federated Press, September 21, 2006, June 14, 2007, January 13, 2009, January 18, 2010, January 26, 2011, and January 2012
Presentation entitled “Canadian Tax Implications of Selected Hybrid Entities”, as part of 8th Canadian National Conference of Society of Trust and Estate Practitioners, June 12, 2006.
“Computing Income from FIEs”, Society of Trust and Estate Practitioners, September 12, 2005
Participant in “Estate Freeze from Hell” presentation, as part of 6th Canadian National Conference of Society of Trust and Estate Practitioners, June 7, 2004.
“Canadian Tax Considerations for Businesses Expanding To the U.S.”, Lorman Seminar on Cross-Border Tax Issues, November 17, 2000, and November 16, 2001
“FIEs- Anomalies, Problems and Pitfalls”, Society of Trust and Estate Practitioners, July 10, 2000
“Closing the Tax-Free Offshore Pipeline”, Society of Trust and Estate Practitioners National Conference, October 20, 1999
“Taxation Of Offshore Trusts: Impact of Proposed Changes-December 23, 1998 and February 16, 1999”, Society of Trust and Estate Practitioners, March 1, 1999
“Investment in U.S. Rental Real Estate-Canadian Tax Implications”, 1998 Ontario Tax Conference, Canadian Tax Foundation
“Estate Freezing and other Issues” as part of case study presented at 1991 Ontario Tax Conference of Canadian Tax Foundation.
Guest speaker at 1992 Bar Admission Course of Law Society of Upper Canada on taxation of deceased taxpayers and trusts.
“Effective Utilization of Tax Losses” paper presented for United Jewish Welfare Fund in June 1991.
Dinner speaker for York District and North York Chartered Accountants Association in 1991, 1992, 1994, 1995 and 1998.
Guest speaker at 1992 Bar Admission Course of Law Society of Upper Canada on taxation of deceased taxpayers and trusts.
“Loss Utilization Planning”, as part of Real Estate Taxation conference presented by The Canadian Institute, February 1991.
“GST and Residential Real Estate”, 1990 Annual Conference, Canadian Tax Foundation
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“GST and Real Estate”, 1990 Ontario Tax Conference, Canadian Tax Foundation
“Income Tax Issues in Real Estate Leasing”, 1989 Corporate Management Tax Conference, Canadian Tax Foundation.
“Planning for the Capital Gains Exemption”, at Small Business Financing and Tax Conference, CCH Canadian Limited, 1986
“Owner/Manager Remuneration”, Small Business Financing and Tax Conference, CCH Canadian Limited, 1985
Tax Topics (published by CCH Canadian Limited)
“Federal Budget Limits Scope of ‘Taxable Canadian Property’ and Creates ‘FIRPTA Canadian Style’”-Issue 1986, April 1, 2010
“Beware of Pitfalls in November 9, 2006 Technical Amendments When Crystallizing ‘Safe Income’ “-Issue 1820, January 25, 2007
“Post-Mortem Tax Planning In Connection With Corporate-Owned Life Insurance”-Issue 1690, July 29, 2004
“Post-Mortem Tax Planning In Connection With Shares of Canadian Private Corporations-More on the ‘Pipeline'”-Issue 1635, July 10, 2003
“New FAPI ‘Fresh Start’ Rules Released-Wording Re Capital Gains Less than Clear; Change of Business Pitfall Added”-Issue 1614 February 13, 2003
“Post-Mortem Tax Planning Using Subsection 164(6) In Connection With Shares Of Canadian Private Corporations”-Issue 1582 July 4, 2002
“CCRA Softens Stance on Late-Filed 216(1) Returns”-Issue 1560 January 31, 2002
“FIE Proposals Will Make FAPI Seem Like Heaven!”-Issue 1480, July 20, 2000
“Watch Out For Those U.S. Pubco Spinoffs!”-Issue 1472, May 25, 2000
“Federal Budget Targets Offshore Trusts”-Issue 1411, March 25, 1999
“The December 23, 1998 Proposals-Impact on Offshore Trusts”-Issue 1404, February 4, 1999
“What’s A CCPC?”-Issue 1378, August 6, 1998
“Sherway Centre Decision May Have Far-Reaching International Tax Implications”-Issue 1374, July 9, 1998
“Federal Budget Proposals May Allow Non-Residents to Repatriate Cost of Shares in Canadian Corporations Tax-Free”-Issue 1365, May 7, 1998
“Remember June 30 Deadline For Most Subsection 216(1) Returns”-Issue 1318-19, June 19, 1997
“Transitional Issues Still Cloud Application of New FAPI Rules”-Issue 1313, May 8, 1997
“Don’t Get Burned By Revised 69(11) When Utilizing Corporate Losses Within The Family!”-Issue 1302, February 21, 1997
“Tax Planning For Trusts with Non-Resident Beneficiaries In Light of October 2, 1996 Proposals-Part II”-Issue 1287, November 7, 1996
“Tax Planning For Trusts with Non-Resident Beneficiaries In Light of October 2, 1996 Proposals-Part I”-Issue 1285, October 24, 1996
“Shift To 5% Treaty Rate on Dividends from Canadian Subsidiaries May Facilitate Global Tax Planning”-Issue 1258, April 18, 1996
“The New Spousal Rollover in the Canada-U.S. Tax Treaty-Part II”-Issue 1253, March 14, 1996
“The New Spousal Rollover in the Canada-U.S. Tax Treaty-Part I”-Issue 1252, March 7, 1996
“Tax Planning For Foreign Inheritances”-Issue 1247, February 1, 1996
“Canada Widens Power To Tax Non-Residents’ Capital Gains-Very Quietly!”-Issue 1212, June 1, 1995
Offshore Finance Canada
“Avoiding Canadian Taxation of Business Profits Treated as FAPI”, Volume No. 3, No. 6, November/December 1998
“Offshore Planning In the Family Business”, Volume 3, No. 2, March/April 1998
International Tax (published by CCH Canadian Limited)
“Route Taken In Going Public Can Affect Non-Residents’ Canadian Tax Position”-No. 1, December 2000
Other Publications
“A Canadian Perspective on U.S. LLCs”, LLC Advisor, CCH Incorporated, Issue Number 18, February 27, 1997
Many articles on various aspects of real estate taxation that have appeared in Globe & Mail, Resource, Real Estate Journal, CCIM Canada
Canadian Appraiser, and Toronto Office Leasing Guide.