On Tuesday November 24, 2009, at the Annual Conference of the Canadian Tax Foundation in Toronto, presentations were made by both the Department of Finance and the Canada Revenue Agency (the "CRA"), and the CRA participated in its annual Roundtable question and answer session.

If the CRA Roundtable discussion takes on a theme from one year to the next, perhaps 2005 was the year of the income trust; 2006, the year of safe income and tax shelters; 2007 may have been the year of trusts and SIFTs; and 2008, the year of the Fifth Protocol. As the CRA continues to release guidance on the Fifth Protocol, 2009 may be the year of the unlimited liability corporation or the services permanent establishment. Or maybe it will be remembered as the year of "Evil" Captain Kirk from Star Trek. We'll see, I guess.

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