Canada

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 leads Deloitte Canada's 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 Montreal.

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

Miller Thomson

Scotia Plaza

40 King Street West, Suite 5800

Toronto, ON M5H 3S1

Canada

Tel: +1 416 595 8626

Fax: +1 416 595 8695

Email: dchodikoff@millerthomson.com

Website: www.millerthomson.com

David W Chodikoff is a tax partner and the tax litigation leader of Miller Thomson. David represents individuals and corporations in civil and criminal disputes with revenue authorities on a provincial, national and global basis.

David spent nearly 16 years as counsel and as a Crown prosecutor with the Department of Justice (Canada). David has conducted more than 550 cases before the courts in Canada. He has more than 100 reported decisions.

David is the general editor and contributing co-author of Transfer Pricing and Tax Avoidance (a resource book covering 33 jurisdictions from around the world), published by Sweet & Maxwell, of London, England (2014); David is the general editor and contributing co-author of Tax Litigation (a resource book covering 29 jurisdictions from around the globe), published by Sweet & Maxwell (2013). David is the co-editor and contributing author of Taxation, Valuation and Investment Strategies in Volatile Markets (Toronto: Carswell, 2010), Taxation & Valuation of Technology (Toronto: Irwin Law, 2008), The Tax Advisor's Guide To The Canada-US Tax Treaty (Toronto: Carswell, loose-leaf 2008-) and Advocacy and Taxation in Canada (Toronto: Irwin Law, 2004). At the moment, David is completing his seventh tax book that he is co-authoring with the immediate former Chief Justice of the Tax Court of Canada, The Honourable Justice Gerald Rip.

David is a current member (and the former chair) of the executive committee of the Taxation Section of the Ontario Bar Association. David is in Martindale-Hubbell and is AV Preeminent® Rated. In 2015, David was awarded Dispute Resolution Lawyer of the Year and Tax Litigation Lawyer of the Year (Canada) from ACQ5.

PwC Law

1250 René-Lévesque Blvd. West

Suite 2800

Montréal, QC H3B 2G4

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, 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.

Before 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 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 has received recognition from the International Tax Review for her role as a Canadian tax controversy leader and has also been awarded the Order of Merit from the Civil Law Faculty at University of Ottawa.

Deloitte Canada

100 Queen Street

Suite 1600

Ottawa, ON K1P 5T8

Canada

Tel: +1 613 751 5293

Email: skeshvani@deloitte.ca

Shiraj Keshvani is a partner in Deloitte Canada's transfer pricing and tax controversy practices.

Before joining Deloitte, Shiraj was the chief economist for Canada Revenue Agency's (CRA) Competent Authority Services Division and the national APA coordinator. He has a deep understanding of CRA's policies and procedures, and the CRA perspective and focus on many contentious issues.

During a 15 year career with the CRA, Shiraj held several roles including: positions in the Compliance Research Directorate, the assistant commissioner's office of the Compliance Programs Branch and the International and Large Business Directorate; in the area of transfer pricing, Shiraj started as an economist in the International Tax Division; and held progressively senior positions including senior transfer pricing economist, APA coordinator and chief economist. Shiraj was also a member of the Transfer Pricing Review Committee, which considers taxpayers' compliance with the Canadian legislation.

On the global front, Shiraj was involved in developing Canada's position on international initiatives such as the OECD's work on the taxation of multinational enterprises and, having spent the greater portion of his career with competent authority, gained significant experience reconciling Canadian views on transfer pricing with those of other countries to resolve double tax. More recently, as part of the management team and having responsibility for policy and procedures for the advance pricing agreement (APA) programme, he was actively involved in negotiating the mode of application for the arbitration provisions under the fifth protocol to the Canada-US tax treaty. Shiraj was also one of a few individuals working with the Advisory Panel on Canada's System of International Tax on specific transfer pricing and competent authority issues.

Since joining Deloitte, Shiraj has assisted multinationals and other clients to manage and resolve difficult and contentious tax controversy issues. He has also conducted a number transfer pricing projects, in a variety of industries, involving audit defence, competent authority assistance, APAs as well as planning and documentation studies. These have addressed a wide range of transfer pricing issues including business restructurings and the treatment of intangibles.

Shiraj continues to remain active on the policy front and is now a member of the BIAC Tax Committee (The Business and Industry Advisory Committee to the OECD) and the ICC (International Chamber of Commerce) Commission on Taxation. Shiraj was recently named one of the world's leading transfer pricing advisers by Euromoney/Legal Media Group.

Shiraj holds bachelor's (honours) and master's of arts degrees in economics.

Deloitte Canada

100 Queen Street, Suite 800

Ottawa, ON K1P 5T8

Canada

Tel: +1 613 7515270

Email: jjlefebvre@deloitte.ca

Jean-Jacques Lefebvre is a senior adviser in the transfer pricing and tax controversy practices of Deloitte LLP (Deloitte Canada). Jean-Jacques is based in Ottawa but serves clients across Canada. He co-leads the tax controversy and dispute resolution practice focusing on developing and implementing tax controversy and dispute resolution strategies for medium size and large corporations as well as high net worth individuals. Since joining Deloitte Canada in January 2010, Jean-Jacques has been involved in addressing and resolving significant tax issues with authorities. He is regularly consulted by senior tax executives and colleagues on tax planning issues and strategies regarding controversy issues arising from both proposed and final assessments. He also contributes frequently on deployment strategies for voluntary disclosure filings.

In his 35 years spent with the Canada Revenue Agency, Jean-Jacques held several senior executive positions. Most recently, Jean-Jacques served as the director general, International and Large Business Directorate (ILBD). In this role he was responsible for providing policy and programme direction to the CRA's field auditors, and, as one of Canada's delegated competent authorities, he was responsible for the administration of Canada's Income Tax Conventions. On the global front, during his tenure, Jean-Jacques served as the chairman of the Seven Country Working Group on Tax Havens, the Canadian lead for the Joint International Tax Shelter Information Centre (JITSIC) and the Seven Country Competent Authority Working Group. In his capacity as director general, Jean-Jacques was also the senior Canadian delegate to OECD's Working Party 6 (Taxation of Multinational Enterprises) and Working Party 8 (Tax Avoidance & Tax Evasion).

Jean-Jacques has tremendous experience with the Canada Revenue Agency's compliance efforts and a deep understanding of its policies and procedures. His extensive knowledge of CRA operations, in both headquarters and regional functions, is of considerable interest for his tax controversy and dispute resolution clients.

Jean-Jacques earned a bachelor's of administration from the University of Ottawa and is a certified public accountant (CPA).

PwC Law

111-5th Avenue SW, Suite 3100

Calgary, AB T2P 5L3

Canada

Tel: +1 403 509 6386

Toll free: +1 800 993 9971

Fax: +1 403 509 7588

Email: patrick.lindsay@ca.pwc.com

Website: pwc.com/taxcontroversy

Patrick Lindsay, a partner in PwC Law, 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 before proceedings reach litigation, by negotiating with tax authorities. ??

Patrick earned his law degree at the University of Calgary and his master's degree in tax from York University. Before joining PwC, Patrick served in a management role at Canada largest national law firm. He is a former president of the Canadian Petroleum Tax Society, former chairman of the Canadian Bar Association tax subsection and teaches corporate tax at the University of Calgary Faculty of Law where he hosts an annual trial competition among law students in connection with a local charity. Patrick has been lead counsel in many successful, reported decisions, including the leading Canadian case on the taxation of financial derivatives. ?

Patrick is a frequent writer and speaker on tax topics and has received several awards, including Lexpert's award for being one of Canada's top lawyers, in any area of practice, under the age of 40 and he is listed in several legal directories as a leading practitioner in corporate tax and tax litigation.

PwC Law

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/ca

Andrew 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 Euromoney Guide to the World's Leading Transfer Pricing Advisers 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.

Deloitte Tax Law

181 Bay Street

Bay Wellington Tower - Brookfield Place

Suite 1400

Toronto, ON M5J2V1

Canada

Tel: +1 416 601 5969

Fax +1 416 601 676

Email: dmuha@deloittetaxlaw.ca

Website: www.deloittetaxlaw.ca

David C Muha is a senior tax litigator and co-founding partner of the Toronto office of Deloitte Tax Law LLP. David has more than 16 years' experience as a lawyer specialising in the areas of tax controversy and tax litigation.

David's objective is to help his clients resolve their tax disputes as efficiently as possible, by negotiating favourable settlements with the tax authorities or, when necessary, by bringing appeals and applications in the courts. David has represented clients in proceedings in the Tax Court of Canada, Federal Court of Canada, Federal Court of Appeal, Supreme Court of Canada and the provincial Superior Courts. David also has a specialty in assisting taxpayers with applying to the courts for rectification of transactions with unintended tax consequences and with applications for judicial review of decisions made by tax authorities. A significant part of his practice involves the management of large and complex tax audits, ensuring that the tax authorities operate within the lawful parameters regarding demands for information and documents, and negotiating arrangements for taxpayers to provide security in lieu of payment for assessed taxes while the assessments are under dispute.

A major focus of David's practice involves the management and litigation of transfer pricing and cross-border tax disputes.

David was admitted to the Law Society of British Columbia in 1998 and to the Law Society of Upper Canada in 2000, after receiving his bachelor of laws from the University of Victoria in 1997. He is a former adjunct professor at the University of Western Ontario, and is a frequent speaker at conferences and seminars regarding tax controversy and litigation. His clients consist primarily of large domestic and multinational corporations, including several Canadian and international financial institutions, insurance companies and Fortune 500 companies.

Deloitte LLP

850 – 2nd Street SW, Suite 700

Calgary, AB T2P 0R8

Canada

Tel: +1 403 267 1859

Email: mnavikenas@deloitte.ca

Markus Navikenas is a partner and an economist in the transfer pricing services practice in Deloitte Canada's 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 analyses 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 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.

Deloitte LLP

181 Bay Street

Bay Wellington Tower – Brookfield Place

Suite 1400

Toronto, ON M5J 2V1

Canada

Tel: +1 416 601 6316

Fax: +1 416 601 6706

Email: rooconnor@deloitte.ca

Website: www.deloitte.com

Rob O'Connor is a Deloitte Canada tax partner based in Toronto. He has 28 years of public accounting experience, including 25 years with Deloitte, providing transfer pricing and corporate income tax planning services to some of Canada's largest corporations that are members of multinational corporate groups.

Rob has held various leadership roles over the last 10 years including Toronto practice leader, Canadian practice leader and Global Managing Director – Transfer Pricing, DTTL (Deloitte Touche Tohmatsu Ltd).

Rob is a former member of the faculty of the Canada Institute of Chartered Accountants (CICA) International Tax course. He is also a frequent speaker and author on international transfer pricing, tax risk management and other tax issues. Rob appears in Euromoney's Guide to the World's Leading Transfer Pricing Advisers and Guide to the World's Leading Tax Advisers.

Rob's tax and transfer pricing experience includes planning and competent authority and advance pricing agreement (APA) engagements, dealing with the Canada Revenue Agency (CRA) on tax and transfer pricing issues, 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.

Rob is a chartered professional accountant (CPA). He earned a bachelor's of mathematics from the University of Waterloo.

Deloitte Tax Law LLP

Brookfield Place

181 Bay Street, Suite 1400

Toronto, ON M5J 2V1

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 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, 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, honours BA 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, and Canadian Bar Association.

PwC

1250 René-Lévesque Boulevard West

Suite 2800

Montréal, QC H3B 2G4

Canada

Tel: +1 514 205 5271

Email: marc.vanasse@ca.pwc.com

Website: pwc.com/taxcontroversy

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

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.