Tax Law Services, Disputes Ontario tax appeals and resolution

Transfer Pricing




  • Speaker on transfer pricing at Canadian Association of Importers and Exporters Cross-Border Tax Forum in Toronto on May 17, 2005;
  • Author of The Litigation of a Transfer Pricing Case published by Irwin in Advocacy in Taxation Law in October 2004;
  • Panel member at The Canadian Institute's Advanced Forum on Transfer Pricing, Resolving Disputes with the CCRA: What Are Your Options?, Toronto, May, 2004
  • Author of The $3 Billion Question, 2004 Vol. 12, No. 3, Canadian Tax Highlights published by Canadian Tax Foundation
  • Author of How to Deal with Transfer Pricing Disputes: Appeals to the Tax Court of Canada, Chapter 22.1, 2002 Conference Report, Canadian Tax Foundation
  • Panel member of September, 2002 Canadian Tax Foundation program on How to Resolve Transfer Pricing Disputes
  • Developer / presenter of transfer pricing courses for CCRA International Auditors
  • Acted as Federal Government's lead counsel in transfer pricing case in Tax Court appeal of SmithKline Beecham Animal Health Inc. v. The Queen, 95-1077(IT)(G)
  • Also acted as counsel for the Crown in several other transfer pricing appeals including Squibb Canada Inc. v. The Queen, AMP of Canada, Ltd. v. The Queen, Crestbrook Forest Industries Ltd. v. The Queen and Cudd Pressure Control Inc. v. The Queen (which also involved the deductibility of "rent" as a notional expense)
  • Experience assisting CCRA International Auditors with the development of audits
  • Completed Multinationals and Transfer Pricing Course, Centre for International Research and Training, Carleton University

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