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Canada

16 August 2017

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Tony Anderson

Deloitte Canada

1005 Skyview Drive, Suite 200
Burlington, ON L7P 5B1
Canada

Tel: +1 905 315 6731
Fax: +1 905 315 6700
Email: toanderson@deloitte.ca
Website: www.deloitte.com

Tony Anderson, Deloitte Canada, is a partner and economist with the national transfer pricing team. Tony leads Deloitte's transfer pricing practice for the Ontario region and Deloitte's transfer pricing team serving private companies nationally.

Tony has more than 21 years of professional experience as a transfer pricing specialist with Deloitte. Tony has assisted numerous multinational companies across various industries in establishing and defending their transfer pricing policies to the Canadian and foreign tax authorities through audit defence, appeals, competent authority and APA cases. Tony has been involved in and led successful dispute resolutions in more than 50 transfer pricing controversy cases.

In addition to leading the preparation of both the economic and functional analyses for documentation and tax controversy purposes, Tony has been significantly involved in strategically evaluating, planning and implementing tax and business efficient transfer pricing policies.

Tony leads Deloitte Canada's transfer pricing team specialised in providing transfer pricing services to private companies and also brings his extensive experience in the automotive industry to many automotive clients as a member of Deloitte Canada's core automotive team. He has served many North American, European and Japanese-based auto manufacturers, distributors and automotive parts suppliers in the transfer pricing controversy arena.

Tony is also a core member of Deloitte's Japanese and Korean services groups, specialising in providing professional services to Japanese and Korean-based multinational clients.

Tony holds a chartered financial analyst (CFA) certificate, a Master of Arts degree in economics from the Simon Fraser University, and a Bachelor of Arts degree in economics from the Wilfrid Laurier University.

He has been a speaker at various transfer pricing conferences organised by the Institute for International Research, CITE, Acumen as well as various Deloitte tax and transfer pricing seminars.


Natan Aronshtam

Deloitte Canada

Bay Adelaide East
22 Adelaide Street West, Suite 200
Toronto, ON M5H 0A9
Canada

Tel: +1 416 643 8701
Fax: +1 416 601 6706
Email: naronshtam@deloitte.ca
Website: www.deloitte.com

Natan Aronshtam, Deloitte Canada, is the global managing director for R&D and government incentives service. Natan regularly leads national and international engagements and serves many of the leading companies in Canada and around the world.

Natan and his team provide services in more than 50 countries, assisting companies with access to government incentives for R&D, investment in new or expanded operations or products, and human resources. Natan also advises governments all over the world on policy and incentive design to increase innovation and attract specific industries and types of businesses.

Natan uses his broad international experience to successfully resolve some of the most complex disputes related to tax and non-tax incentives.


Patrick Bilodeau

Deloitte Canada

100 Queen Street, Suite 1600
Ottawa, ON K1P 5T8
Canada

Tel: +1 613 7515447
Email: pbilodeau@deloitte.ca
Website: www.deloitte.com

Patrick Bilodeau, Deloitte Canada, leads the Ottawa and Eastern Canada international tax practice. He advises his clients in dealing with reviews and challenges from tax authorities, and in particular, in respect of cross-border considerations. He works closely with his tax controversy and transfer pricing colleagues throughout Canada and leverages his broad network of colleagues in countries on all continents with the goal of resolving these complex cross-border matters for his clients.

Patrick's background as a tax lawyer and a chartered professional accountant (CPA), along with his experience as a tax adviser on complex transactions, allows him to bring a unique and integrated approach to tax controversy. He has assisted clients with representations as part of Canada Revenue Agency audits, appeals procedures and voluntary disclosures for a wide variety of matters. He also works closely with Deloitte's transfer pricing controversy experts to assist clients with mutual agreement procedure (MAP) considerations.

Patrick has advised multiple Canadian-based and foreign multinationals on international and Canadian taxation issues. He has developed a deep specialism in implementing cross-border transactions and structures to help his clients navigate the complexities of international business, including the engineering of tax efficient international corporate structures, cross-border mergers and acquisitions and international intellectual property and financing structures. Patrick frequently advises Canadian businesses looking to expand internationally and works closely with his clients to align the implemented tax structure with their business objectives.

Patrick obtained his law degree (summa cum laude) from the University of Ottawa, and is both a member of the Quebec Bar and a CPA. Patrick also has a Master of Laws – taxation option – degree from HEC Montreal and the University of Montréal.

Patrick has contributed to various publications such as the Bloomberg BNA International Tax Forum and the Revue de l'APFF. He also frequently speaks on complex international tax matters.


Olivier Fournier

Deloitte Tax Law LLP

La Tour Deloitte
1190 avenue des Canadiens-de-Montréal
Suite 500
Montréal, QC H3B 0M7
Canada

Tel: +1 514 393 8362
Fax: +1 514 390 1808
Email: olfournier@deloittetaxlaw.ca
Website: www.deloittetaxlaw.ca

Olivier Fournier, Deloitte Canada, leads the Montréal office. Olivier practices tax law with a focus on tax litigation and tax controversy, from the audit and objection stages to tax appeals before the courts. He regularly assists clients in resolving tax disputes, both in and out of court, and engages in managing complex tax audits, ensuring that the tax authorities operate within the lawful parameters regarding demands for information and documents and correcting non-compliance issues. He also has had significant exposure to tax planning for domestic and international mergers and acquisitions.

He has acted in matters before the Tax Court of Canada, the Court of Québec, the Federal Court and the Federal Court of Appeal.

He is an active speaker, writer and presenter at various conferences and seminars, such as for the Association de Planification Fiscale et Financière (APFF) and the Canadian Tax Foundation (CTF).

Olivier was called to the Bar of Québec in 2006, after receiving an MBA from the University of Ottawa (2005), and an LLL in 2005 (magna cum laude) and a BSc (Biology) in 2002 from the University of Ottawa.


Richard Garland

Deloitte Canada

22 Adelaide Street West, Suite 200
Toronto, ON M5H 0A9
Canada

Tel: +1 416 601 6026
Fax: +1 416 -601 6706
Email: rgarland@deloitte.ca
Website: www.deloitte.com

Richard Garland, Deloitte Canada, is a partner in the Toronto office. He is a chartered professional accountant and has more than 30 years of accounting experience focused in the areas of transfer pricing and international taxation.

Richard has assisted clients in all aspects of international taxation, with particular emphasis on tax treaty issues, cross-border financing structures and transfer pricing. Over the past several years, Richard's work has been focused in the area of transfer pricing. He has assisted clients in various industries with all aspects of transfer pricing, including planning studies, documentation studies, audit defence and controversy, competent authority matters, and advance pricing agreements. Richard has extensive experience assisting clients in dealing with complex transfer pricing issues related to intangibles and research and development.

Richard is a member of the firm's technology, media and telecommunications tax practice and works closely with the firm's international tax specialists in developing and implementing tax efficient strategies for ownership of intellectual property. Richard is also a member of the firm's energy and resources industry tax practice, and has extensive experience assisting clients in various sectors of the resource industry.

He achieved his bachelor's degree in mathematics from the University of Waterloo. He is a member of the Institute of Chartered Accountants of Ontario and Canadian Tax Foundation.


Laurie Goldbach

Deloitte Tax Law LLP

700, 850-2 Street SW
Calgary, AB T2P 0R8
Canada

Tel: +1 403 503 1488
Fax: +1 403 920 9333
Email: lgoldbach@deloittetaxlaw.ca
Website: www.deloittetaxlaw.ca

Laurie Goldbach is a partner at the law firm of Deloitte Tax Law LLP. Her practice focuses on tax litigation, tax controversy and defending criminal tax prosecutions. She has extensive trial and appellate advocacy experience and regularly appears before all levels of courts in Alberta, and has appeared before the Tax Court of Canada, the Federal Court of Canada and the Supreme Court of Canada.

Laurie has twice been recognised by Legal Media Group's Benchmark Canada as a future star. She also has been highlighted in International Tax Review's Women in Tax Leaders guide.

Laurie was admitted to the Law Society of Upper Canada and to the Law Society of Alberta in 2000. She received her Bachelor of Laws from the University of Victoria in 1998. She is also an active writer, speaker and presenter at conferences and seminars in the legal community. Laurie has taught for a number of years at the University of Calgary's Faculty of Law. She is also a regular instructor at the Alberta Bar admission course (CPLED).

She is a member of the Canadian Bar Association, the Canadian Petroleum Tax Society and the Canadian Tax Foundation.


Nathalie Goyette

PwC Law LLP Barristers and Solicitors

1250 René-Lévesque Blvd. West, suite 2500
Montréal, QC H3B 4Y1
Canada

Tel: +1 514 205 5321
Email: nathalie.goyette@ca.pwc.com
Website: www.pwc.com/ca/law

Nathalie Goyette is a resident partner in the Montréal office of PwC Law, an independent tax and immigration law firm affiliated with PwC.

Nathalie has more than 25 years of experience in managing and resolving audit and appeal disputes involving the provincial and federal tax authorities. She assists clients with every aspect of tax audits and represents them before courts.

Prior to joining PwC Law, Nathalie was a partner in a major Canadian law firm and, before that, she acted as a senior tax lawyer with the Federal Department of Justice.

Nathalie received her LLL from the University of Ottawa, her LLB from Dalhousie University and her master's degree in taxation from Sherbrooke University.

Nathalie has written for numerous publications, is a frequent speaker in Canada and abroad, and is a member of the rules committee of the Tax Court of Canada. She is also a member of the Barreau du Québec, Canadian Tax Foundation, International Fiscal Association, and Association de planification fiscale et financière.

Nathalie is ranked annually in International Tax Review's Tax Controversy Leaders guide for Canada and she is listed as a recommended lawyer by Lexpert. Nathalie received the Order of Merit from the Civil Law Faculty of the University of Ottawa.


Gerald Grenon

Osler, Hoskin & Harcourt

450 – 1st St. S.W.
TransCanada Tower
Suite 2500
Calgary, AB T2P 5H1
Canada

Tel: +1 403 260 7014
Email: ggrenon@osler.com
Website: www.osler.com

Gerald Grenon is a partner in the firm's taxation practice. His practice encompasses all stages of tax dispute resolution from dealing with Canada Revenue Agency (CRA) audits to litigating in court. Gerald has appeared before the Tax Court of Canada, Federal Court of Appeal, Supreme Court of Canada and Alberta Court of Queen's Bench, including such well-known cases as Canada Trustco v. The Queen (which remains the only Supreme Court of Canada decision on the general anti-avoidance rule (GAAR) in which a taxpayer was successful), Shell Canada v. The Queen (where the Supreme Court of Canada held that the Crown was not allowed to tax on substance over form, interest deduction was allowed and so was gain on hedge capital) and 3850625 Canada Inc (formerly Fording Coal) v. The Queen (where the Federal Court of Appeal held that refund interest increased the taxpayer's resource allowance deduction).

Gerald has been recognised by the Canadian Legal Lexpert Directory as being consistently recommended in the area of litigation – corporate tax (2017). He has also been recognised by the Best Lawyers in Canada in the area of tax law (2017).


Andrew Kingissepp

Osler, Hoskin & Harcourt

100 King Street West
1 First Canadian Place
Suite 6200, PO Box 50
Toronto ON M5X 1B8
Canada

Tel: +1 416 862 6507
Email: akingissepp@osler.com
Website: www.osler.com

Andrew Kingissepp specialises in taxation with a focus on dispute resolution, including managing transfer pricing audits, informal appeals and tax litigation. His practice is conducted largely on a confidential basis as he generally seeks to resolve major tax disputes on behalf of clients prior to the litigation stage. However, he has pursued litigation on behalf of clients when necessary and has had a major role in two of the largest Canadian transfer pricing cases (Irving Oil and Cameco). Andy has written and presented papers on a number of income tax subjects, including transfer pricing, at various seminars and conferences.

He is recognised as one of the leading authorities in the management of income tax audits and disputes in Canada and has been called upon to present on this subject at leading tax conferences in Canada with the Canadian Tax Foundation, International Fiscal Association and others. He is also the Canadian correspondent for the Journal of International Taxation and has written extensively for that publication, as well as others.


Norma Kraay

Deloitte Canada

Bay Adelaide East, 22 Adelaide Street West, Suite 200
Toronto, ON, M5H 0A9
Canada

Tel: +1 416 601 4678
Fax: +1 416 601 6151
Email: nkraay@deloitte.ca
Website: www.deloitte.com

Norma Kraay, Deloitte Canada, is a lead tax partner with more than 22 years of professional experience in tax-related matters, including the last 20 years as a transfer pricing expert. Norma was appointed as the Canadian transfer pricing leader in June 2017.

Norma is a trusted adviser to numerous multinational enterprises. She is recognised for successfully guiding companies through large and complex transfer pricing disputes, including advising companies on their advance pricing agreements and mutual agreement procedures with revenue authorities. In this capacity, Norma has assisted multinational enterprises with comprehensive strategies for global tax disputes, including information gathering and data management, documentation, compiling and preparing submissions, leading discussions with revenue authorities and dealing with secondary adjustments and post-settlement matters. Over the years, Norma has also advised her clients through their business cycles, including end-to-end M&A transactions, global expansions, transfer pricing planning engagements, designing operational transfer pricing systems and policies, assisting enterprises with financial transactions and advising on restructuring transactions involving intangible property. Norma has been recognised as one of the world's leading transfer pricing advisers in Euromoney's Transfer Pricing Expert Guide since 2015.

Norma has a BBA from Instituto Tecnologico Autonomo de Mexico (ITAM), a graduate degree from the international tax programme at Harvard Law School and a master's degree in public administration from the Harvard Kennedy School at Harvard University.

Norma is an active participant in the community. In addition to undertaking speaking engagements at various industry and tax professional associations, such as the Tax Executive Institute, she has written a number of articles including publications in Tax Notes International and Bloomberg BNA Tax Management International. Norma is a member of the Canadian Tax Foundation. She is also a former director of the board of the Canadian Association of Importers and Exporters, former member of the corporate committee for the Art Gallery of Ontario and currently serves on the audit committee of The Loran Scholars Foundation.


Patrick Lindsay

PwC Law LLP

111-5th Avenue SW, Suite 3100
Calgary, AB T2P 5L3
Canada

Tel: +1 403 509 6386
Email: patrick.lindsay@pwc.com
Website: www.pwc.com/ca/law

Patrick Lindsay is an advocate for clients in tax matters. He frequently appears in court to litigate substantive tax issues and to defend taxpayer rights. He also helps clients resolve tax disputes prior to litigation by negotiating with tax authorities.

Patrick's recent cases include:

  • Birchcliff Energy Ltd. v The Queen, 2017 FCA 89 – The issue is whether the general anti-avoidance rule (GAAR) can apply to override the normal operation of the loss streaming rules and eliminate $39 million in tax attributes and the taxpayer succeeded at the Federal Court of Appeal;
  • George Weston Limited v The Queen, 2015 TCC 42 – Patrick successfully overturned a long-standing position held by the Canada Revenue Agency (CRA), regarding the taxation of derivatives, resulting in a favourable tax treatment on the disposition of C$2 billion ($1.5 billion) in cross-currency swaps; and
  • Ollenberger v The Queen, 2013 FCA 74 – Patrick successfully defended entitlement to an allowable business investment loss where the CRA disputed whether the relevant oil and gas company carried on an "active business".

Patrick has a LLM (tax law) from Osgoode Hall Law School and an LLB from the University of Calgary, 2001.

Patrick has worked with a variety of public and private company clients in the oil and gas, real estate and other industries. He is active in the Calgary business community and is a past president of the Canadian Petroleum Tax Society. Patrick is ranked annually in International Tax Review's Tax Controversy Leaders guide for Canada. He also is identified in the Lexpert Directory for his expertise in corporate tax and is a former chair of the Canadian Bar Association tax specialists subsection. He was previously honoured by the Lexpert as a "Rising Stars Leading Lawyers under 40".

Patrick is active in the market as a speaker and writer on tax issues, including recent presentations and publications for the Canadian Tax Foundation, the Tax Executives Institute, CPA Canada, the Society of Trust and Estate Practitioners and the Canadian Bar Association.


Andrew McCrodan

PwC

PwC Tower
18 York Street
Suite 2600
Toronto, ON M5J 0B2
Canada

Tel: +1 416 869 8726
Fax: +1 416 814 3200
Email: andrew.f.mccrodan@ca.pwc.com
Website: www.pwc.com/taxcontroversy

Andrew McCrodan is a transfer pricing partner with PwC's Toronto office. He has been with the firm for more than 30 years and has been a partner since 1997. He began his career in transfer pricing in PwC's New York office in 1994, assisting companies in complying with the first US contemporaneous documentation requirements and now specialises in transfer pricing controversy and dispute resolution.

His extensive cross-border experience includes prospective studies for planning purposes, income tax audit defence, contemporaneous documentation engagements, competent authority assistance, and advance pricing agreements (APAs). He has helped clients in obtaining unilateral and bilateral APAs in a variety of industries, including mining, manufacturing, automotive, entertainment, retail, and software.

Andrew is a CPA and a chartered business valuator (CBV). As a CBV, Andrew brings a wealth of valuation experience to international restructuring, cost sharing, and intellectual property migration assignments.

The Transfer Pricing Expert Guide published by Euromoney, Legal Media Group, has featured Andrew since 2003, and in 2011 he was voted one of the "Best of the Best", a ranking of the top five advisers in Canada.

As a leader in the field, Andrew speaks regularly on transfer pricing and business valuation topics for a number of professional organisations. He has also written articles for CA Magazine, the Canadian Tax Foundation, the Journal of Business Valuation, and Tax Planning International Review. He co-authored "The dilemma of GlaxoSmithKline: Unreasonable in the circumstances?" and "Transfer pricing: A critique of the CRA's position on range issues", both published by the Canadian Tax Foundation.


Al Meghji

Osler, Hoskin & Harcourt

100 King Street West
1 First Canadian Place
Suite 6200, PO Box 50
Toronto ON M5X 1B8
Canada

Tel: +1 416 862 5677
Email: ameghji@osler.com
Website: www.osler.com

As a partner and head of the tax controversy practice at Osler, Al Meghji is widely regarded as Canada's preeminent tax litigation counsel, holding an outstanding record of success in complex tax litigation matters in various courts. Al is supported by Osler's tax group, which is consistently ranked as one of Canada's largest and most sophisticated tax practices.

Al has been lead counsel in many of Canada's most important and high-profile tax cases. He has appeared in the Supreme Court of Canada more frequently than any other Canadian tax litigator and has successfully argued a number of landmark tax cases in that court, including Shell Canada (widely regarded as the leading authority on economic substance and tax avoidance); Canada Trustco (that defined the scope of the Canadian general anti-avoidance rule (GAAR)); and GlaxoSmithKline (the first and only transfer pricing case heard by the Supreme Court of Canada).

He is tax litigation counsel of choice for significant Canadian and multinational enterprises. Al is also lead counsel in a number of complex transfer pricing cases proceeding through the courts, including several cases that will be the first to test Canada's re-characterisation rule and transfer pricing penalty provision.

Al has been widely recognised as a leading Canadian tax litigation practitioner by third-party and peer review legal ranking directories, including Chambers Canada (2017), Best Lawyers in Canada (2017), Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada (2017) and the Tax Directors Handbook. He is the only tax litigator in Canada to receive the coveted "Star Individuals" rating by Chambers Global (2017). Al was also recognised by Best Lawyers as "Tax Lawyer of the Year" and by Best of the Best 2015: Expert Guides as "one of the world's top 30 tax practitioners".

Al is a CPA and a graduate of Harvard Law School (LLM). He was previously counsel in the tax litigation section of the Department of Justice. He is a sought-after speaker on matters of tax litigation and trial advocacy, and appears regularly in the media on tax matters of significance both nationally and globally.


David Muha

Deloitte Canada

Bay Adelaide East
22 Adelaide Street West, Suite 200
Toronto, ON M5H 0A9
Canada

Tel: +1 416 601 5969
Fax: +1 647 497 6865
Email: dmuha@deloittetaxlaw.ca
Website: www.deloittetaxlaw.ca

David Muha is a senior tax litigator practising exclusively in the area of tax controversy and tax litigation, and is a co-founding partner of the Toronto office of Deloitte Tax Law LLP. Dave is recognised in International Tax Review's Tax Controversy Leaders guide as one of Canada's leading tax litigation practitioners. He is a former adjunct professor at the University of Western Ontario's Faculty of Law and is a frequent speaker on tax controversy issues at various conferences and seminars.

Dave's practice encompasses all aspects of tax controversy and tax litigation, including management of large and complex tax audits, disputing tax assessments through administrative appeals or litigation in the courts, voluntary disclosures, applications for judicial review of decisions of tax authorities and applications in the provincial courts for the rectification of transactions with unintended tax consequences. Dave has represented clients in proceedings in the Tax Court, Federal Court, Federal Court of Appeal and the Provincial Superior Courts in a wide variety of such tax matters. A significant portion of his practice involves the management and litigation of transfer pricing and cross-border tax disputes.

After receiving his Bachelor of Laws from the University of Victoria in 1997, Dave was admitted to the Law Society of British Columbia in 1998 and to the Law Society of Upper Canada in 2000. His clients consist primarily of large domestic and multinational enterprises, including several Canadian and foreign financial institutions, Fortune 500 companies and other public multinationals.


Markus Navikenas

Deloitte Canada

850 – 2nd Street SW, Suite 700
Calgary, AB T2P 0R8
Canada

Tel: +1 403 267 1859
Email: mnavikenas@deloitte.ca
Website: www.deloitte.com

Markus Navikenas, Deloitte Canada, is a partner and an economist in the transfer pricing services practice in the Calgary office. Markus has significant experience in transfer pricing and business model optimisation (BMO), dealing with the tax authority on transfer pricing issues, and assisting clients with developing dispute resolution and audit strategies.

Markus has developed transfer pricing analysis and documentation for numerous Canadian and US multinationals in the energy sector. His experience spans a wide range, from developing transfer pricing policies and studies to assisting taxpayers with developing strategies for transfer pricing audits. He also assists multinationals with responding to tax authorities on transfer pricing matters including voluntary disclosures, advance pricing arrangements, and obtaining relief from double taxation.

Markus holds his MA from the University of Victoria, his MBA from the University of Western Ontario's Richard Ivey School of Business and he has been the co-dean of Deloitte's Global Transfer Pricing School. Markus has written numerous articles and frequently speaks on the topic of transfer pricing and intellectual property for the Council for International Tax Education, Canadian Association of Petroleum Producers, Calgary Petroleum Tax Society, Deloitte's Global Tax Roundtable, Acumen, as well as the Economic Society of Calgary.

He was recognised by Euromoney as one of the leading transfer pricing advisers, globally, in 2013.


Rob O’Connor

Deloitte Canada

Bay Adelaide East
22 Adelaide Street West, Suite 200
Toronto, ON, M5H 0A9
Canada

Tel: +1 416 601 6316
Email: rooconnor@deloitte.ca
Website: www.deloitte.com

Rob O'Connor, Deloitte Canada, is a tax partner based in Toronto. He has 31 years of public accounting experience, including 28 years with Deloitte. Rob is involved in providing income tax services including transfer pricing services and advice to Canadian and foreign corporations that are members of multinational corporate groups.

The majority of Rob's practice has been focused on providing transfer pricing services and advice since Canada introduced revised transfer pricing rules in 1997. Over that 20-year period, Rob has held various leadership roles within Deloitte including Toronto transfer pricing practice leader, Canadian transfer pricing practice leader and global managing director – transfer pricing, DTTL (Deloitte Touche Tohmatsu Ltd). Rob is a member of Deloitte's global business tax leadership team.

He is a frequent speaker and author on international transfer pricing and related tax issues. Rob appears in Euromoney's Transfer Pricing Expert Guide, the Best of the Best for Transfer Pricing and Tax Advisers Expert Guide.

Rob's tax and transfer pricing experience includes planning and CA/APA engagements, dealing with the Canada Revenue Agency (CRA) on tax and transfer pricing issues and assisting clients to compile and present information to support transfer prices and develop audit defence strategies. Rob has assisted clients in a wide variety of industries. He has been involved in many projects dealing with the reorganisation or restructuring of global operations and the movement of functions, risks and ownership of assets.

Rob has also been involved in many specialised tax consulting projects, particularly involving cross-border transactions, acquisitions, divestitures and inbound investment in Canada.

He is a chartered professional accountant and has a bachelor's degree in mathematics from the University of Waterloo.


Clifford Rand

Deloitte Tax Law LLP

Bay Adelaide East
22 Adelaide Street West, Suite 200
Toronto, ON M5H 0A9
Canada

Tel: +1 416 775 8830
Fax: +1 647 497 6865
Email: crand@deloittetaxlaw.ca
Website: www.deloittetaxlaw.ca

Clifford Rand is the national managing partner and leader of the national tax litigation practice of Deloitte Tax Law LLP. Cliff is recognised as a leading tax litigation practitioner in the Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada, the International Tax Review's Tax Controversy Leaders guide, and the Lexpert Guide to the Leading US/ Canada Cross-border Litigation Lawyers. He is a frequent speaker, writer and presenter at various conferences and seminars.

Cliff is a member of the law societies of Ontario and Alberta. He specialises in managing large and complex tax audits, including audits involving corporate reorganisations, cross-border transactions, transfer pricing, R&D credits, and the general anti-avoidance rule. One important part of Cliff's practice is ensuring that the tax authorities operate within lawful parameters regarding demands for information and documents, and representing clients in applications to the courts for judicial review of decisions made by tax authorities regarding access to information and other issues. Cliff also assists clients in correcting non-compliance issues and in rectifying transactions with unintended tax consequences.

Cliff's main practice objective is to help his clients resolve their tax disputes as efficiently as possible, by helping them negotiate favourable settlements with the tax authorities or, when necessary, by bringing appeals and applications in the courts.

Cliff is a graduate of Osgoode Hall Law School (LLM 1986) and McGill University (LLB 1981, BA with honours 1977). He first began practising law in Calgary, Alberta in 1982 and, for a few years in the mid-1980s, was a law professor at the University of Windsor.

Cliff is a member of the Canadian Tax Foundation, International Fiscal Association, Advocates' Society, and Canadian Bar Association.


Marc Vanasse

PwC

1250 René-Lévesque Boulevard West
Suite 2500
Montréal, QC H3B 4Y1
Canada

Tel: +1 514 205 5271
Email: marc.vanasse@pwc.com
Website: pwc.com/taxcontroversy

Marc Vanasse, CPA, CA, is the national leader of PwC's tax dispute resolution team.

Marc's many years working at the Canada Revenue Agency (CRA) before joining PwC greatly benefits his clients, through insight and assistance in all areas of tax controversy and favourable dispute resolution.

Because of his unique experience, Marc is a popular speaker at conferences both nationally and globally.

Marc has a wealth of knowledge and experience in many areas of Canada's income tax system, having spent more than 20 years in the income tax rulings directorate of the CRA.

He has also served as a member of the CRA's general anti-avoidance rules (GAAR) committee (1999-11).

Marc has worked with the Department of Finance on numerous legislative changes including tax shelters, partnerships, corporate reorganisations, income trusts and green energy initiatives. He met regularly with CRA appeals officers and Department of Justice lawyers to discuss cases proceeding to court and reviewed notices of reply/appeal and related briefings on topics such as corporate distributions, transaction costs, contingent liabilities, trusts and the GAAR.

Marc has mediated numerous technical tax disputes between CRA auditors and taxpayers in his role as a senior executive within the rulings directorate on issues ranging from employee/shareholder benefits to corporate surplus stripping, resource taxation and estate planning. Marc was instrumental in managing and issuing numerous complex and sensitive advance income tax rulings and interpretations.

Marc has also represented the CRA as a speaker at numerous tax conferences and seminars, including those sponsored by the Canadian Tax Foundation, the Tax Executives Institute, and l'Association de Planification Fiscale et Financière.


François Barette
Fasken Martineau DuMoulin

Neil Bass
Aird & Berlis

Dominic Belley
Norton Rose Fulbright

Jacques Bernier
Baker McKenzie

Monica Biringer
Osler, Hoskin & Harcourt

Nathan Boidman
Davies Ward Phillips & Vineberg

Michel Bourque
KPMG

Wendy Brousseau
McCarthy Tetrault

Alexandra Brown
Blake, Cassels & Graydon

Michael Bussman
Gowling WLG

Maurice Chiasson
Stewart McKelvey

David Chodikoff
Miller Thomson

Chia-yi Chua
McCarthy Tetrault

Nicolas Cloutier
McCarthy Tetrault

Louis-Frédérick Côté
Spiegel Sohmer

Carrie D'Elia
Osler, Hoskin & Harcourt

Guy Du Pont
Davies Ward Phillips & Vineberg

Kristen Duerhammer
KPMG

Tim Fitzsimmons
PwC

Étienne Gadbois
Dentons

Cheryl A Gibson QC
Dentons

Serge Gloutnay
Serge Gloutnay

Geoff Hall
McCarthy Tetrault

Jehad Haymour
Dentons

Amanda Heale
Osler, Hoskin & Harcourt

David Kemp
Collins & Barrow

Ed Kroft
Blake, Cassels & Graydon

Justin Kutyan
KPMG

Wilfrid Lefebvre
Norton Rose Fulbright

Paul Lynch
KPMG

Martha MacDonald
Torys

Peter Macdonald
Osler, Hoskin & Harcourt

Bill Maclagan
Blake, Cassels & Graydon

Jenny Mboutsiadis
Fasken Martineau DuMoulin

Janice McCart
Blake, Cassels & Graydon

Carman R McNary QC
Dentons

Pooja Mihailovich
Osler, Hoskin & Harcourt

Warren Mitchell QC
Thorsteinssons

Al-Nawaz Nanji
Osler, Hoskin & Harcourt

Joel A Nitikman
Dentons

Stevan Novoselac
Gowling WLG

Yves Ouellette
Gowling WLG

Jean-François Perreault
Fasken Martineau DuMoulin

Sébastien Rheault
Barsalou Lawson Rheault

David Robertson
EY

Edward Rowe
Osler, Hoskin & Harcourt

Daniel Sandler
EY

Alan M Schwartz
Fasken Martineau DuMoulin

Jeffrey Shafer
Blake, Cassels & Graydon

Nicolas Simard
Fasken Martineau DuMoulin

Ken Skingle QC
Felesky Flynn

John Sorensen
Gowling WLG

Yves St-Cyr
Dentons

Joe Starnino
Starnino Mostovac

Craig Sturrock
Thorsteinssons

Paul Tamaki
Blake, Cassels & Graydon

Louis Tassé
EY

Roger Taylor
EY

Deborah Toaze
Blake, Cassels & Graydon

Mark Tonkovich
Baker McKenzie

Joanne Vandale
Osler, Hoskin & Harcourt

Scott Wilkie
Blake, Cassels & Graydon

Matthew Williams
Thorsteinssons

John Yuan
McCarthy Tetrault






International Tax Review Profile

Margrethe Vestager once again showing why she's in the #GlobalTax50 with today's announcement of an investigation i… https://t.co/ncyjcWUUE8

Dec 18 2017 01:07 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @JP_Owens: Delighted to see #WUGTPC featured in #GlobalTax50 by @IntlTaxReview https://t.co/CMax2lIkvU Congrats to other colleagues in…

Dec 18 2017 12:53 ·  reply ·  retweet ·  favourite
International Tax Review Profile

So, ITR readers. Will the US tax reform bill make it to Trump's desk by Christmas?

Dec 18 2017 11:17 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @EU_Competition: State aid: @EU_Commission opens in-depth investigation into the Netherlands' tax treatment of Inter IKEA https://t.co/b

Dec 18 2017 11:12 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @EU_Commission: We have opened an in-depth investigation into the Netherlands' tax treatment of Inter IKEA, one of two groups operating…

Dec 18 2017 11:12 ·  reply ·  retweet ·  favourite
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