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Canada

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 over 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.


Neil Bass

Dentons

77 King Street West
Suite 400
Toronto, Ontario M5K 0A1
Canada

Tel: +1 416 863 4757
Email: neil.bass@dentons.com
Website: www.dentons.com

Neil Bass is highly acclaimed in the fields of tax litigation and commodity taxation, including goods and services tax and harmonised sales tax (GST/HST), provincial sales tax (PST), and international customs duties, and is the leader of Dentons' national tax group.

He has extensive experience in dealing with various taxation authorities and has represented clients before the Canadian International Trade Tribunal, the Tax Court of Canada, the Federal Court and Federal Court of Appeal, as well as before provincial courts. Neil served on the CBA/CICA joint legislation review committee that examined the draft legislation that amended the Canadian Excise Tax Act.

Neil has written numerous articles and conference papers on the GST/HST and was a co-editor of 'Canadian GST and Commodity Tax Cases' published by CCH Canada.

Neil has been recognised as a leading practitioner in the area of commodity tax in prominent legal and other professional directories including, most recently, International Tax Review.

Neil continues to address audiences on a variety of commodity tax matters and is a past presenter at the CICA Commodity Tax Symposium and the Canadian Tax Foundation Conference. Neil was also awarded the 1999 Normand Guerin Award for his "outstanding contribution to the study of commodity taxation".


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 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 CRA 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 IP 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 BNAInternational Tax Forum and the Revue de l'APFF. He also frequently speaks on complex international tax matters.


Donald GH Bowman, QC

Dentons

77 King Street West
Suite 400
Toronto, Ontario M5K 0A1
Canada

Tel: +1 416 863 4620
Email: donald.bowman@dentons.com
Website: www.dentons.com

As former chief justice of the Tax Court of Canada, Donald GH Bowman has extensive experience in resolving tax disputes. He is counsel to Dentons' national tax group and shares his expertise with members of the group as a mentor and adviser.

Based in the firm's Toronto office, Donald works to enhance the firm's ability to reach early resolution of tax and related disputes for the firm's clients. His practice at Dentons consists of giving advice on tax matters including tax litigation to clients, lawyers in the firm throughout Canada and to lawyers in other firms.

Donald has spent his entire legal career as a tax litigator. He joined the Federal Department of Justice – Tax Litigation Section soon after his call to the Ontario Bar and was appointed director in 1968. He joined the law firm of Stikeman, Elliott, Robarts & Bowman in 1971 and was a partner there until his appointment to the Tax Court of Canada. He was appointed judge of the Tax Court of Canada in 1991 and associate chief judge in February 2000. He was appointed associate chief justice in July 2003 and chief justice in February 2005


Olivier Fournier

Deloitte Canada

La Tour Deloitte
1190 avenue des Canadiens-de-Montréal
Suite 500
Montréal (Québec) 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


Étienne Gadbois

Dentons

1 Place Ville Marie
39th Floor
Montréal, Quebec H3B 4M7
Canada

Tel: +1 514 878 8880
Email: etienne.gadbois@dentons.com
Website: www.dentons.com

Étienne Gadbois is a tax partner in Dentons' Montréal office. He is recognised as one of the most frequently recommended Canadian lawyers in the area of commodity tax and customs by the Canadian Legal Lexpert Directory and as an international leader in the areas of indirect tax and tax disputes by International Tax Review.

Étienne practises in the commodity tax area and has recognised expertise in federal and provincial sales taxes, including Canada's goods and services tax (GST), harmonised sales tax (HST), Québec sales tax (QST), as well as land transfer taxes, fuel, carbon, alcohol, tobacco, and other similar taxes.

Étienne is regularly involved in negotiations, client representations and interventions with the Canada Revenue Agency, Québec tax authority, the Court of Québec, the Tax Court of Canada and the provincial and federal appeals courts. His practice also involves providing advice in the areas of commodity taxes in mergers and acquisitions, corporate reorganisations, real estate transactions, joint ventures and the structuring of public-private partnerships.

Widely recognised for his distinctive expertise, Étienne is regularly asked to speak at various forums and is a widely published author in textbooks and academic journals on topics related to consumption taxes (and VAT in general) and tax disputes. Since 2013, Étienne has written two Carswell, Thomson Reuters publications: 'La Loi du Praticien annotée – TPS-TVQ' (Practitioner's GST/QST Annotated Act), which is updated twice a year, and a monthly bilingual newsletter on new trends in commodity taxes. More recently, he co-authored the book entitled 'Le litige fiscal au Québec et au Canada'. Finally, Étienne founded La Revue des taxes à la consummation, a commodity tax journal that is published quarterly, where he acts as editor-in-chief.


Cheryl A Gibson, QC

Dentons

2900 Manulife Place
10180 – 101 Street
Edmonton, Alberta T5J 3V5
Canada

Tel: +1 780 423 7310
Email: cheryl.gibson@dentons.com
Website: www.dentons.com

As former head of Dentons' Edmonton tax group, Cheryl A Gibson practises in numerous facets of taxation law.

She has extensive experience in the resolution of income tax and goods and services tax (GST) disputes including criminal tax evasion matters. Cheryl focuses on getting results in a timely and efficient manner.

Cheryl also plans and implements tax-driven corporate reorganisations and the establishment of trusts. She advises on pension matters and has prepared opinions on numerous tax and GST topics.


Laurie Goldbach

Deloitte Canada

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, Deloitte Canada, 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

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

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

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 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 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.

In addition, Nathalie received recognition from International Tax Review for her role as a tax controversy leader and the Order of Merit from the Civil Law Faculty at the University of Ottawa


Jehad Haymour

Dentons

850 – 2nd Street SW
15th Floor, Bankers Court
Calgary, Alberta T2P 0R8
Canada

Tel: +1 403 268 7162
Email: jehad.haymour@dentons.com
Website: www.dentons.com

Jehad Haymour is a partner and tax department manager for Dentons' Calgary office.

He has practiced in the area of tax litigation for over 20 years and has represented clients before the tax authorities, the Tax Court of Canada, the Federal Court of Appeal, and the Supreme Court of Canada.

Jehad is recognised by Lexpert, Best Lawyers, Legal 500, Chambers Global: The World's Leading Lawyers for Business and International Tax Review's World Tax as a leading lawyer in the area of tax litigation and has extensive experience in taxation issues specific to the energy sector. His experience also includes advice related to tax reporting and structuring on various energy-based projects.


David Kemp

Collins Barrow (Canadian member of Baker Tilly International)

Collins Barrow Place
11 King Street West, Suite 700
Toronto, ON M5H 4C7
Canada

Tel: +1 647 725 1741
Email: dkemp@collinsbarrow.com
Website: www.collinsbarrow.com

David Kemp is a partner and leader of the global transfer pricing and dispute resolution services practice at Collins Barrow (Canadian member of Baker Tilly International), based at the Toronto office. He is also a member of Baker Tilly International's global transfer pricing committee, which oversees the development of transfer pricing globally within the firm.

David has over 20 years of experience in the areas of global transfer pricing, including corresponding international tax planning strategies, income tax and financial advisory. During this time he has advised multinational enterprises, within a broad scope of industries, on transfer pricing planning, documentation and dispute resolution matters. He has advised clients on a full spectrum of cross-border transactions, including tangible assets, intangible assets, intellectual property, services, financial transactions, management fees and cost reimbursements.

From a transaction perspective, David has significant experience regarding the identification and assessment of intangible assets and intellectual property, as well the evaluation of financial transactions and corresponding determination of loan interest rates and guarantee fees. From an industry perspective, David has considerable experience regarding investment advisory and fund management companies, including the determination of advisory, sub-advisory, distribution, management and related service fees.

He has successfully defended transfer pricing policies under audit by Canadian and foreign taxation authorities, encompassing field audit negotiations, Notice of Objection appeals, Competent Authority submissions and advanced pricing arrangements (APAs).

David has been acknowledged as one of the leading transfer pricing advisers in the world by outside legal counsel and peer review, and has been repeatedly included in Euromoney's guide to the world's leading transfer pricing advisers. David has also been acknowledged as one of the leading tax dispute advisers around the world, and has been included in International Tax Review'sTax Controversy Leaders guide.

David is a chartered professional accountant and has a bachelors degree in commerce. He is a member of the Chartered Professional Accountants of Canada, Canadian Tax Foundation, International Fiscal Association and Licensing Executives Society.


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 East
Toronto, ON M5H 4E3
Canada

Tel: +1 416 601 4678
Fax: +1 416 601 6706
Email: nkraay@deloitte.ca
Website: www.deloitte.com

Norma Kraay, Deloitte Canada, is a tax partner with over 20 years of professional experience in tax-related matters, including the last 19 years as a transfer pricing expert. In addition to practicing in the area of transfer pricing, Norma is the Canadian industry tax leader for consumer and industrial products.

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 global tax dispute strategies, 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 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.

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 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 board of The Loran Scholars Foundation.


Patrick Lindsay

PwC Law LLP

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

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

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:

  • 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;
  • Birchcliff Energy Ltd. v The Queen, 2015 TCC 232 – This case was under appeal to the Federal Court of Appeal. The issue was 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
  • 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 an LLM in 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 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 CBA tax specialists subsection. He was also honoured by the Lexpert as one of the "Rising Stars Leading Lawyers under 40" in 2014.

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 PricingExpert 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


Carman R McNary, QC

Dentons

2900 Manulife Place
10180 – 101 Street
Edmonton, Alberta T5J 3V5
Canada

Tel: +1 780 423 7236
Email: carman.mcnary@dentons.com
Website: www.dentons.com

Carman R McNary is the managing partner of the Edmonton office. He concentrates his practice primarily in the areas of taxation and corporate law, with emphasis on compliance and dispute resolution with government agencies, and on corporate tax strategies, structures and governance of tax risk, particularly focusing on First Nations and cross-border enterprises. Carman chaired Dentons' national tax practice group from 2002 to 2012.

Carman acts for Canadian and international companies advising on tax efficient structures and effective tax management. This includes advice to First Nations and in respect of structures with First Nation enterprises as well as advice in respect of cross-border investment into and from Canada, private and public transactions, structures and taxation issues, and including acquisitions, divestitures and reorganisations, transfer pricing and withholding taxes.

Assisting clients with audits, objections to the Canada Revenue Agency and appeals to courts when required, Carman works to resolve tax related disputes at the earliest level. He has appeared before the Supreme Court of Canada and extensively before the Tax Court of Canada, the Federal Court Trial Division and Federal Court of Appeal, and all levels of court within Alberta, on matters relating to income tax, goods and services tax (GST) and other commodity taxes.

Carman is a member of the board of private corporations as well as not-for-profit organisations, including past chair of the Edmonton Community Foundation and chair of the Alberta Chambers of Commerce. He is a frequent speaker on tax matters. From 2001 to 2006, he was a sessional lecturer in taxation for the Faculty of Law at the University of Alberta. He has been recognised by Best Lawyers in Canada 2013 as "Lawyer of the Year" in tax law (Edmonton) and as one of Canada's leading lawyers in the area of tax law in 2013, 2014 and 2015.


Al Meghji

Osler, Hoskin & Harcourt

100 King Street West
1 First Canadian Place
Suite 6200, P.O. 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 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 (2016), Best Lawyers in Canada (2016), Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada (2016) and the Tax Directors Handbook. He is the only tax litigator in Canada to receive the coveted "Star Individual" rating by Chambers Global and Chambers Canada (2016). 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

Dave Muha, Deloitte Canada, is a senior tax litigator with over 17 years' experience practicing in the area of tax controversy and tax litigation, and is a co-founding partner of the Toronto office. 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' specialisms cover a broad number of issues including determining pricing for intercompany loan interest rates, guarantee fees, receivables factoring, and energy and foreign exchange hedging transactions. He has also established royalty rates for the transfer of intellectual property (IP) involving coiled tubing technologies, seismic 2D and 3D, trademarks, trade names, horizontal drilling know-how, corporate brands, and patents.

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 IP 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.


Joel A Nitikman

Dentons

250 Howe Street
20th Floor
VancouverBritish Columbia V6C 3R8
Canada

Tel: +1 604 443 7115
Email: joel.nitikman@dentons.com
Website: www.dentons.com

Joel A Nitikman is a tax partner. He has extensive experience in tax litigation and resolving disputes between taxpayers and governmental tax authorities. He has litigated in the Supreme Court of Canada and settled many cases before trial.

Joel's skills include organising, analysing and structuring complex data to determine the relevant tax issues, preparing witnesses, drafting pleadings and arguments, excellent oral advocacy and legal research, persuading and reasoning in a complex environment and assimilating a large number of facts quickly. Joel is listed as a leading tax litigator by Lexpert.

Joel also practices corporate, individual and international tax planning, including cross-border tax planning for the entertainment industry, offshore trusts, Canada-US corporate reorganisations, Canadian investment in the US, US investment in Canada and cross-border estate planning. Joel advises on goods and services tax (GST) and provincial commodity taxes. Joel is listed as a leading corporate tax lawyer by Lexpert.

Joel has obtained numerous advance rulings from tax authorities. His abilities include creativeness and thinking 'outside the box' in creating new structures to achieve tax efficiency. Joel has advised non-profit and other tax exempt entities, including Crown corporations. Joel has structured public offerings of tax-related securities. Joel has acted as an expert tax witness in civil litigation for plaintiffs and defendants and has developed the ability to simplify and explain complex technical tax issues.

Joel has written and presented many tax-related articles. He was awarded the Sherbaniuk Award for an article on rectification. Joel is a former governor of the Canadian Tax Foundation and a member of the CRA/CBA committee, the CBA/CPA joint committee and the federal bench and bar committee.


Rob O'Connor

Deloitte Canada

Bay Adelaide Centre, East Tower
22 Adelaide Street WestSuite 200
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 30 years of public accounting experience, including the last 27 years with Deloitte Tax Law LLP in Canada. Rob provides income tax services and specifically 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 this period, Rob has held various leadership roles within Deloitte, including Toronto transfer pricing practice leader, Canadian transfer pricing practice leader, global managing director-transfer pricing, and member of Deloitte's global transfer pricing executive team.

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 frequent speaker and writer 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 the Tax Advisers Expert Guide.

Rob is a chartered professional accountant and has a bachelors degree in mathematics from the University of Waterloo


Clifford Rand

Deloitte Canada

Bay Adelaide East
22 Adelaide Street WestSuite 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, Deloitte Canada, is the national managing partner and leader of the national tax litigation practice in Canada. 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 was called to the Bar in Ontario in 1986 and in Alberta in 1982. He has a particular specialty in assisting clients in managing large and complex tax audits, including audits involving corporate reorganisations, the general anti-avoidance rule (GAAR), cross-border transactions and transfer pricing. 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.


Yves St-Cyr

Dentons

77 King Street West
Suite 400
Toronto, Ontario M5K 0A1
Canada

Tel: +1 416 863 4712
Email: yves.stcyr@dentons.com
Website: www.dentons.com

Yves St-Cyr is a partner in Dentons' Toronto office, and a member of the firm's national tax law group. For the past 25 years, Yves' practice has focused on tax litigation and dispute resolution. Prior to joining the private sector, he practiced at the Federal Department of Justice. He is a member of the Bar in both Québec and Ontario.

Yves has argued many tax cases before the Tax Court of Canada, Federal Court, Federal Court of Appeal, Court of Québec, Québec Superior Court, and Québec Court of Appeal. He has also made written representations to the Supreme Court of Canada.

Yves has experience requesting interpretations or rulings from the tax authorities, and filing and negotiating voluntary disclosures. He prepares submissions, on behalf of his clients, to the tax authorities at both the audit level and the objection stage of an assessment, and assists his clients in negotiating settlements. He also obtained remission orders and has made representations to the Department of Finance regarding proposed tax legislation amendments.

Yves previously lectured at the Chartered Professional Accountants of Canada Tax Symposium, the Fiscal and Financial Planning Association, and the Tax Executive Institute. He has also taught taxation at the University of Québec in Montréal.


Marc Vanasse, CPA, CA

PwC

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

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

Marc Vanasse is the national leader of PwC's tax dispute resolution team, and is managing tax partner in Montréal.

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 GAAR committee (1999-2011).

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 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.


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