Canada

77 King Street West

Suite 400

Toronto, ON M5K 0A1

Canada

Direct line: +1 416 863 4757

Email: neil.bass@dentons.com

Website: www.canadiantaxlitigation.com

Neil Bass is the national chair of Dentons' national tax group and 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. 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 reviewed the draft legislation which amended the Canadian Excise Tax Act.

Neil has authored 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 Limited. 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".

For more information about us, please visit our tax controversy blog at www.canadiantaxlitigation.com.

Year of call: 1990 (Ontario)

77 King Street West

Suite 400

Toronto, ON M5K 0A1

Canada

Direct line: +1 416 863 4620

Email: donald.bowman@dentons.com

Website: www.canadiantaxlitigation.com

As a former chief justice of the Tax Court of Canada, the Honourable Donald 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 our 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.

He is frequently recommended by The 2010-2014 Canadian Legal Lexpert Directory as a leading lawyer in the area of corporate tax litigation. He is also recognised by the 2013/2014 Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada as a leading lawyer in the area of corporate tax litigation and recognised in Best Lawyers in Canada 2013 and 2014 as one of Canada's leading lawyers in the area of tax law.

For more information about us, please visit our tax controversy blog at www.canadiantaxlitigation.com

Year of call: 1962 (Ontario); 1982 (New York)

199 Bay Street, Suite 4000

Commerce Court West

Toronto, ON M5L 1A9

Canada

Tel: +1 416 863 2637

Fax: +1 416 863 2653

Email: alexandra.brown@blakes.com

Website: www.blakes.com

Alexandra Brown is a senior litigator specialising in tax litigation with broad experience in both public service and private practice. Before joining Blakes, she was a partner at a boutique firm and served as senior counsel at the Department of Justice (Canada), where she practised for more than 20 years.

Alexandra has represented domestic and international clients at all stages of disputes with federal and provincial revenue authorities, disputes involving complex issues such as the general anti-avoidance rule and transfer pricing. She has appeared at all levels of court including the Supreme Court of Canada.

Alexandra is a frequent speaker to professional groups including the Ontario Bar Association, Canadian Tax Foundation, and The Advocates' Society, as well as law schools across the province. Her presentations have covered a wide range of corporate income tax issues as well as advocacy matters.

• Canadian Legal Lexpert® Directory: Most frequently recommended practitioner in corporate tax litigation

• Lexpert®/American Lawyer Guide to the Leading 500 Lawyers in Canada

• Chambers Global: The World's Leading Lawyers for Business: Tax litigation

• Lexpert® Guide to the Leading US/Canada Cross-Border Litigation Lawyers in Canada

Scotia Plaza

40 King Street West, Suite 5800

Toronto, ON M5H 3S1

Canada

Direct line: +1 416 595 8626

Fax: +1 416 595 8695

Email: dchodikoff@millerthomson.com

Website: www.millerthomson.com

David Chodikoff is a partner at Miller Thomson, a pan-Canadian law firm. David represents individuals and corporations in civil and criminal disputes with revenue authorities.

David spent nearly 16 years as counsel and as a Crown prosecutor with the Department of Justice (Canada). David has conducted more than 540 cases before the courts in Canada and has more than 100 reported decisions.

David is the co-editor and contributing author of Tax Litigation (London: Sweet & Maxwell, 2013), Taxation, Valuation and Investment Strategies in Volatile Markets (Toronto: Carswell, 2010), Taxation & Valuation of Technology (Toronto: Irwin Law, 2008), The Tax Adviser'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 sixth book entitled Transfer Pricing and Tax Avoidance. This forthcoming publication is part of the European Lawyer Reference Series; it is a resource book covering 33 jurisdictions from around the world.

David was a former chairman of the executive committee of the Taxation Section of the Ontario Bar Association. In 2013 and 2014, David was selected as a leading practitioner and included in the Lexpert Legal Directory for his work in the areas of corporate tax litigation. David is in Martindale-Hubbell and is AV Preeminent® Rated.

2900 Manulife Place

10180 – 101 Street

Edmonton, AB T5J 3V5

Canada

Direct line: +1 780 423 7310

Email: cheryl.gibson@dentons.com

Website: www.dentons.com

As former head of Dentons' Edmonton tax group, Cheryl Gibson's practice encompasses all aspects of taxation law. She plans and implements tax-driven corporate reorganisations and the establishment of trusts, and represents taxpayers at every stage of the process. She advises on pension matters and has prepared opinions on numerous tax and GST topics. Cheryl has appeared before the Tax Court of Canada, Federal Court of Appeal, Provincial Court (Alberta) and Court of Queen's Bench (Alberta).

Cheryl's extensive experience in the resolution of income tax and GST disputes includes: taxation of aboriginal persons and businesses; matters specific to the construction industry; access to the small business deduction; taxation of internet businesses; transfer pricing; timing of income receipts and expense claims; employee benefits; employee versus independent contractor; voluntary disclosures; income tax and GST evasion defence; and matters specific to charities and non-profit organisations.

She is repeatedly recommended by The Canadian Legal Lexpert Directory 2013-2014 as one of Canada's leading lawyers in the area of corporate tax. She is recommended by Best Lawyers in Canada 2010, 2011, 2012, 2013 and 2014 as one of Canada's leading lawyers in the area of tax law, and was named 'Lawyer of the Year' by Best Lawyers 2014 in tax law in Edmonton. Cheryl was appointed Queen's Counsel in 2012.

For more information about us, please visit our tax controversy blog at www.canadiantaxlitigation.com.

Year of call: 1991 (Alberta, Ontario)

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.wilsonandpartners.ca

Nathalie Goyette is a resident partner in the Montréal office of Wilson & Partners, an independent tax law firm affiliated with PwC.

Nathalie has more than 20 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 Wilson & Partners, 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.

1 Place Ville Marie

39th Floor

Montreal, QC H3B 4M7

Canada

Direct line: +1 514 878 8851

Email: jean.groleau@dentons.com

Website: www.canadiantaxlitigation.com

Jean Groleau practises tax law from Dentons' Montreal office. His practice focuses on litigation before civil and administrative courts.

Jean represents both individuals and companies in matters relating to sales and income taxes, penal and criminal charges arising from tax offences and collection, and in numerous matters relating to administrative and constitutional law. Jean brings to his practice an in-depth knowledge of the workings of the Minister of Revenue that he acquired during his eight years as crown counsel. Jean frequently lectures at events organised by the Canadian Tax Foundation and the Association de planification fiscale et financière (APFF). He is member of the APFF of which he was previously member of the board and president.

Jean is co-founder and chairman of the board of administration of the Ataxia of Charlevoix-Saguenay Foundation. He is also a member of the Canadian Tax Foundation and a former member of the board of directors of the Sainte-Justine Hospital Foundation.

Jean is recognised as a leading tax controversy lawyer in Canada by International Tax Review's Tax Controversy Leaders Guide (Canada) 2011, 2012, 2013 and 2014.

For more information about us, please visit our tax controversy blog at canadiantaxlitigation.com

Year of call: 1989 (Quebec)

850 – 2nd Street SW

15th Floor, Bankers Court

Calgary, AB T2P 0R8

Canada

Direct line: +1 403 268 7162

Email: jehad.haymour@dentons.com

Website: www.canadiantaxlitigation.com

Jehad Haymour leads the tax practice for Dentons' Calgary office. For more than 20 years, he has practised in the area of tax litigation 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 Chambers Global: The World's Leading Lawyers for Business, International Tax Review's World Tax and Best Lawyers in Canada as a leading lawyer in the area of tax litigation and has extensive experience in dealing with taxation issues specific to large corporations, including taxation issues relating to the energy sector. His experience also includes significant tax structuring and transactional advice on various energy-based projects, and general advice on taxation issues specific to the energy sector.

For more information about us, please visit our tax controversy blog at www.canadiantaxlitigation.com

Year of call: 1991 (Alberta)

100 Queen Street

Suite 1600

Ottawa, ON K1P 5T8

Canada

Tel: +1 613 751 5293

Email: skeshvani@deloitte.ca

Website: www.deloitte.com

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 Programmes 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, and 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 issues. More recently, as part of the management team and having responsibility for policy and procedures for the advance pricing arrangement (APA) programme, he was actively involved in negotiating the mode of application for the arbitration provisions under the fifth protocol to the Canada-US 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 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 a bachelor's (honours) and master's of arts degrees in economics.

100 Queen Street, Suite 800

Ottawa, ON K1P 5T8

Canada

Tel: +1 613 7515270

Email: jjlefebvre@deloitte.ca

Website: www.deloitte.com

Jean-Jacques Lefebvre, or JJ as he is commonly known, is a partner in Deloitte Canada's global transfer pricing and tax controversy practice. 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 possesses a BA from the University of Ottawa and is a certified public accountant.

150 Elgin Street, Suite 1800

Ottawa, ON K2P 2P8

Canada

Bay Adelaide Centre

333 Bay Street Suite 4600

Toronto, ON M5H 2S5

Canada

Tel: +1 613 212 3795

Email: plynch@kpmg.ca

Website: www.kpmg.com/ca

Paul Lynch is a chartered accountant and a member of the KPMG national tax practice in Canada and the Canadian contact for KPMG's international tax dispute resolution network. He is a national partner in the firm's tax services practice in Canada (based in the Ottawa office) and he leads the tax dispute resolution and controversy practice for KPMG Canada.

Paul joined KPMG from the Canada Revenue Agency (CRA). Before his departure from the CRA, Paul was acting assistant commissioner for the Appeals Branch. Among other roles in the audit and rulings functions of the CRA, Paul served as director general of the Tax and Charities Appeals Directorate. In this role, Paul was the final authority for settling the most significant tax disputes, for setting Appeals Branch policies and procedures and for directing the most sensitive litigation for the CRA. Paul was also the secretary for the CRA GAAR Committee, and also led the CRA's review and developed the CRA's position on interest deductibility.

Paul knows and understands the internal processes of the CRA, and the flow of files from audit to dispute resolution (competent authority and/or appeals) and litigation, and can provide insight and support, tactically and strategically, on how best to resolve disputes.

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 recently celebrated 32 years with the firm, 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.

His extensive cross-border experience includes prospective studies for planning purposes, income tax audit defences, 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 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 has co-authored 'The Dilemma of GlaxoSmithKline: Unreasonable in the Circumstances?' and 'Transfer Pricing: A Critique of the CCRA's Position on Range Issues', both published by the Canadian Tax Foundation.

2900 Manulife Place

10180 – 101 Street

Edmonton, AB T5J 3V5

Canada

Direct line: +1 780 423 7236

Email: carman.mcnary@dentons.com

Website: www.dentons.com

Carman McNary is managing partner of the firm's 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. Carman chaired Dentons' national tax practice group from 2002 to 2012.

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, GST and other commodity taxes.

Carman also 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, to cross-border investment into and from Canada, and to private and public transactions, structures and taxation issues, including acquisitions, divestitures and reorganisations, transfer pricing and withholding taxes.

Carman is a member of the board of private corporations as well as not-for-profit organisations, including his role as chairman of the Edmonton Community Foundation. He is a frequent speaker on tax matters. From 2001 to 2006, he was a member of the Faculty as a sessional lecturer in taxation for the Faculty of Law, University of Alberta. He was 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 and 2014. He received the well-regarded distinction and recognition as Queen's Counsel.

For more information about us, please visit our tax controversy blog at www.canadiantaxlitigation.com.

Year of call: 1982 (Alberta)

250 Howe Street

20th Floor

Vancouver, BC V6C 3R8

Canada

Direct line: +1 604 443 7115

Email: joel.nitikman@dentons.com

Website: www.canadiantaxlitigation.com

Joel Nitikman is a partner in the tax group at Dentons. For almost 30 years, Joel's practice has focused on resolving tax disputes between taxpayers and federal and provincial tax authorities. Joel has extensive experience in federal and provincial income/commodity tax litigation. He has acted as counsel in numerous tax cases at all levels of court, both provincially and federally. He has also settled many cases out of court at the pre-assessment or objection stage.

Joel's skills include organising a complex set of data, analysing and structuring the data to determine the relevant tax issues, preparing witnesses for court, drafting legal pleadings and substantive arguments, excellent oral advocacy skills, excellent legal research, the ability to persuade and reason in a complex environment and the ability to assimilate a large number of facts quickly. Joel is listed as one of Canada's leading tax litigation lawyers by Lexpert. Joel also practises corporate and individual business tax, focusing on offshore tax planning, corporate reorganisations and other business-related tax matters. Joel also advises on GST and provincial commodity taxes. Joel is listed as one of Canada's leading corporate tax lawyers by Lexpert. Joel has been involved in extensive provincial, federal and international income and commodity 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 has obtained numerous advance rulings from the Canada Revenue Agency and provincial tax authorities. Joel's abilities include creativity and the ability to think outside the box in creating new structures to achieve maximum tax efficiency. Joel has advised on non-profit and other tax exempt entities, including Crown corporations and trusts. Joel has had extensive involvement with structuring and opening on public offerings of tax-related securities. Joel has acted as an expert tax witness in civil litigation for plaintiffs and defendants and, in doing so, has developed the ability to simplify and explain complex technical tax issues.

Joel has been involved extensively in writing and presenting tax-related articles on international, federal and provincial income tax, GST and retail sales tax issues. He was awarded the 2006 Douglas J. Sherbaniuk Distinguished Writing Award by the Canadian Tax Foundation for his article 'Many questions (and a few possible answers) about the application of rectification in tax law' (2005) in vol. 53, no 4 Canadian Tax Journal 941-73. Joel is a former governor of the Canadian Tax Foundation and is now a member of a number of different tax committees, including a joint CRA/CBA committee in the Pacific region of the CRA, the CBA/CICA Joint Committee on Taxation, and the Federal Bench and Bar Committee.

Year of call: 1986 (British Columbia)

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 of 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 CA/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 defense 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. He earned a bachelor's of mathematics from the University of Waterloo.

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.deloitte.com/ca/taxlaw

Clifford Rand is the national managing partner and leader of the national tax litigation practice of Deloitte Tax Law 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, 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.

77 King Street West

Suite 400

Toronto, ON M5K 0A1

Canada

Direct line: +1 416 863 4712

Email: yves.stcyr@dentons.com

Website: www.canadiantaxlitigation.com

Yves St-Cyr is a partner in the Dentons Canada Toronto office, and is a member of the tax law group. His practice focuses on tax litigation (income tax and GST/HST/QST) and on commercial transactions pertaining to corporate reorganisations, financings, and the sale and purchase of business or real estate for GST/HST/QST purposes.

Yves has experience requesting interpretations or rulings from the tax authorities for GST/HST/QST purposes and voluntary disclosures in either income tax or GST/HST/QST matters.

He has argued several income tax and GST/HST/QST cases before the Quebec Court, Quebec Superior Court, Quebec Court of Appeal, Tax Court of Canada, Federal Court, and the Federal Court of Appeal. He has also made written representations to the Supreme Court of Canada.

Yves prepares submissions on behalf of his clients to the tax authorities at both the audit level and the objection stage of an assessment. He also assists clients in obtaining remission orders, or makes representations at the Department of Finance to propose amendments to tax legislation.

Yves is a lecturer at the Chartered Professional Accountants of Canada's Tax Symposium, the Fiscal and Financial Planning Association, and the Tax Executives Institute. He has also taught taxation at the University of Québec in Montréal.

For more information about us, please visit our tax controversy blog at www.canadiantaxlitigation.com

Year of call: 1987 (Quebec); 2011 (Ontario)

850 – 2nd Street SW, Suite 700

Calgary, AL T2P 0R8

Canada

Tel: +1 403 2670503

Email: curstewart@deloittetaxlaw.ca

Website: www.deloitte.com

Curtis Stewart is a senior tax litigator in the Calgary office of Deloitte Tax Law whose practice focuses exclusively on tax litigation and tax dispute resolution. Curtis is recognised as a leading tax litigation practitioner by Chambers Global: The World's Leading Lawyers for Business, by Lexpert Lawyer Guide to Leading Lawyers in Canada and the International Tax Review's Tax Controversy Leaders.

Curtis was called to the Bar in Saskatchewan in 1990 and in Alberta in 2000. Curtis has extensive experience dealing with provincial and federal tax authorities and conducting tax litigation in the Tax Court of Canada and Federal Court of Canada, as well as defending criminal tax prosecutions in Provincial Courts and the Court of Queen's Bench. Curtis has also appeared before the Supreme Court of Canada. Curtis' experience also includes the GST and commodity tax areas.

Curtis is also recognised nationally as a leader in rectifying and correcting transactions with unintended tax consequences. He has published numerous articles in the area of taxation and tax litigation. He has also been a sessional lecturer in tax law at the University of Saskatchewan College of Law.

He is a member of the Rules Committee of the Tax Court of Canada, the Canadian Tax Foundation, the Canadian Petroleum Tax Society, and the Canadian Bar Association

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. Marc was a director of the reorganisations and resources division at the Income Tax Rulings Directorate from 2004 to 2011 and director of the business and partnerships division from 2000 to 2004.

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.