2026 IFA Canada Travelling Lectureship

Toronto - In person: 11:00 AM – 2:45 PM EST

Address: Offices of Gowling WLG
100 King St W Suite 1600
Toronto, ON M5X 1G5

Live: Venues will be announced.

Vancouver - live: 8:00 AM – 11:45 PM PST

Calgary - live: 9:00 AM – 12:45 PM MST

Ottawa - live: 11:00 AM – 2:45 PM EST

Montreal - live: 11:00 AM – 2:45 PM EST

Guest Lecturers:

• Błażej Kuźniacki, Global Tax Policy & International Tax Services at PwC Netherlands | Professor of Law at Lazarski University | Senior Research Affiliate at Singapore Management University
• Robert Raizenne, Tax Partner, Osler, Hoskin & Harcourt LLP,  Adjunct Professor of Tax Law at McGill University’s Faculty of Law, and the Faculty of Law at the University of Toronto

Lectureship Overview:
Beneficial ownership is a fundamental concept in determining a taxpayer’s entitlement to tax treaty benefits.  Longstanding jurisprudence in Canada has recently been reconsidered by the Federal Court of Appeal in Canada.  Speakers Błażej Kuźniacki and Robert Raizenne will discuss the elaboration and historical development of the beneficial ownership concept and the role the concept currently plays in international taxation. The scope of beneficial ownership as defined in sometimes conflicting international jurisprudence and the parameters set by the OECD will be discussed.  The speakers will also comment on its future role in a changing international taxation landscape, addressing continuing uncertainty in this area.