Canada

77 King Street West

Suite 400

Toronto, Ontario M5K 0A1

Canada

Tel: +1 416 863 4757

Fax: +1 416 863 4592

Email: neil.bass@dentons.com

Website: www.dentons.com

Neil Bass, chair of Denton's national tax group, 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.

With extensive experience in dealing with various taxation authorities, Neil 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 Canadian Bar Association/Canadian Institute of Chartered Accountants 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, is on the editorial board of Federated Press' Sales and Use Tax, and was a past co-editor of Canadian GST and Commodity Tax Cases, published by CCH Canada. Neil has been repeatedly recognised as a leading practitioner in the area of commodity tax and tax litigation in prominent legal and other professional directories.

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

Formerly Fraser Milner Casgrain

77 King Street West

Suite 400

Toronto, ON M5K 0A1

Canada

Tel: +1 416 863 4620

Fax: +1 416 863 4592

Email: donald.bowman@dentons.com

Website: www.dentons.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 the 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 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.

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

Formerly Fraser Milner Casgrain

3 Church Street, Suite 505

Toronto, ON M5E 1M2

Canada

Tel: +1 416 981 9424

Fax: +1 416 981 0060

Email: abrown@laishleyreed.com

Website: www.laishleyreed.com

Alexandra Brown is a senior litigator specialising in tax litigation with broad experience in both public service and private practice. Before joining Laishley Reed, Alexandra was a partner in a large national law firm and before that she was 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

PO Box 1011

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 W. Chodikoff is a partner at Miller Thomson. David represents corporations and individuals in civil and criminal disputes with revenue authorities.

A tax litigation specialist, David spent nearly 16 years as counsel and as a Crown prosecutor with the Toronto Regional Office of the Department of Justice (Canada). David has conducted more than 540 cases before the courts in Canada. He has nearly 100 reported decisions.

A prolific writer, David is the co-editor and a 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 fifth book titled Tax Litigation. This forthcoming publication is part of the European Lawyer Reference Series, it is a resource book covering 29 jurisdictions from around the world.

David was a past chair of the executive committee of the Taxation Section of the Ontario Bar Association. In 2013, David was selected as a leading tax practitioner and included in the Canadian Lexpert Legal Directory, Litigation–Corporate Tax.

2900 Manulife Place

10180 – 101 Street

Edmonton, AL T5J 3V5

Canada

Tel: +1 780 423 7310

Fax: +1 780 423 7276

Email: cheryl.gibson@dentons.com

Website: www.dentons.com

As a chartered accountant and lawyer, Cheryl brings unique skills to the practice of tax law. She is the former chair of the Edmonton tax group, and is a governor of the Canadian Tax Foundation. Her practice focuses on income tax and GST dispute resolution, planning and implementation of corporate reorganisations, and estate planning matters, including the use of family trusts.

Cheryl's vast income tax and GST expertise 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 has extensive experience advising businesses on various structures, including corporations, partnerships, joint ventures, and trusts, on doing business with aboriginal groups, and in acting as an arbitrator of business-related disagreements.

Resolving tax disputes effectively and efficiently at the earliest opportunity is Cheryl's strength. She represents taxpayers at the audit stage, objection stage and the appeal stage. Cheryl has appeared before the Tax Court of Canada, Federal Court of Appeal, Provincial Court (Alberta) and Court of Queen's Bench (Alberta).

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

Formerly Fraser Milner Casgrain

1250 René-Lévesque Blvd. West

Suite 2800

Montréal, QC H3B 2G4

Canada

Tel: +1 514 205 5321

Email: nathalie.goyette@ca.pwc.com

Website: pwc.com/taxcontroversy

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

Montréal, QC H3B 4M7

Canada

Tel: +1 514 878 8851

Fax: +1 514 866 2241

Email: jean.groleau@dentons.com

Website: www.dentons.com

Jean Groleau has been practising tax law for more than 15 years and has developed expertise in the field of tax litigation, both from an administrative and judicial point of view. Admitted to the Québec Bar in 1989, he served as Quebec Crown counsel from 1989 to 1997. During this time, he represented the Minister of Revenue in court cases relating to sales and income taxes, penal and criminal charges with respect to tax offences and collection of taxes, and in numerous matters relating to administrative and constitutional law.

Jean is often invited as a lecturer on behalf of both the Canadian Tax Foundation and the Association de Planification Fiscale et Financière (APFF). His philanthropic activities include his membership on the board of directors of the Sainte-Justine Hospital Foundation. He is also co-founder and chair of the board of administration of the Ataxie Charlevoix-Saguenay Foundation.

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

Formerly Fraser Milner Casgrain

850 – 2nd Street SW

15th Floor, Bankers Court

Calgary, AL T2P 0R8

Canada

Tel: +1 403 268 7162

Fax: +1 403 268 3100

Email: jehad.haymour@dentons.com

Website: www.dentons.com

Jehad Haymour has practised in the area of tax litigation for more than 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.

He 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 taxation issues specific to the energy sector. His experience also includes significant tax structuring and transactional advice on various energy-based projects.

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

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

Formerly Fraser Milner Casgrain

100 Queen Street

Suite 800

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 LLP's transfer pricing and tax controversy practices.

Before joining Deloitte, Shiraj was the chief economist for the Canada Revenue Agency's (CRA) Competent Authority Services Division and the national advance pricing agreement (APA) coordinator. He has a deep understanding of the 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 transfer pricing, as an economist in the International Tax Division; 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 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 the competent authority, gained significant experience reconciling Canadian views on transfer pricing with that of other countries to resolve double tax issues.

More recently, as part of the CRA management team, and having responsibility for policy and procedures for the 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 for 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 and 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 remains 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.

Shiraj holds a bachelor's and master's degree in economics.

100 Queen Street, Suite 800

Ottawa, K1P 5T8

Canada

Tel: +1 613 7515270

Email: jjlefebvre@deloitte.ca

Jean-Jacques Lefebvre is a partner in Deloitte LLP'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-Jaques has been involved in addressing and resolving significant tax issues with revenue 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 (CRA), 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 chair 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 the OECD's Working Party 6 (taxation of multinational enterprises) and Working Party 8 (tax avoidance and tax evasion).

Jean-Jacques has tremendous experience with the CRA's compliance efforts and has 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 bachelors of administration degree from the University of Ottawa and is a certified public accountant.

160 Elgin Street, Suite 2000

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 McCrodan is a Toronto based transfer pricing partner with PwC where he devotes the majority of his time to transfer pricing controversy work.

He recently celebrated 30 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 to comply with the first US contemporaneous documentation requirements.

Andrew's 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 technology.

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

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 on the topic of transfer pricing.

He co-authored, the articles The Dilemma of GlaxoSmithKline: Unreasonable in the Circumstances?, and Transfer Pricing: A Critique of the CCRA's Position on Range Issues among others, both published by the Canadian Tax Foundation.

Andrew has appeared in the Guide to the World's Leading Transfer Pricing Advisers since 2003 and was voted one of the Best of the Best top 5 in Canada in 2011.

2900 Manulife Place

10180 – 101 Street

Edmonton, AL T5J 3V5

Canada

Tel: +1 780 423 7236

Fax: +1 780 423 7276

Email: carman.mcnary@dentons.com

Website: www.dentons.com

Carman McNary QC, who chaired Dentons' national tax group from 2002 to 2012, concentrates his practices in the area of taxation with emphasis on compliance and dispute resolution with government agencies, and on corporate tax strategies and governance of tax risk.

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.

Carman not only assists clients with audits and objections to the Canada Revenue Agency, but also represents them in appeals to courts at all levels. 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 cross-border investment into and from Canada, including cross-border acquisitions, divestitures and reorganisations, transfer pricing and withholding taxes.

Carman is a member of the board of numerous corporations as well as not for profit organisations, and 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 law faculty at the University of Alberta.

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

Formerly Fraser Milner Casgrain

250 Howe Street

20th Floor

Vancouver, BC V6C 3R8

Canada

Tel: +1 604 443 7115

Fax: +1 604 683 5214

Email: joel.nitikman@dentons.com

Website: www.dentons.com

Joel Nitikman is a partner in Dentons' national tax group. 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 also practises corporate and individual business tax, focusing on offshore tax planning, corporate reorganisations and other business-related tax matters. Joel advises on GST and provincial commodity taxes and is listed as one of Canada's leading corporate tax lawyers by Lexpert and Best Lawyers in Canada 2013.

Joel has been involved in extensive provincial, federal and international income and commodity tax planning, including cross-border tax planning for the entertainment industry, off-shore trusts, Canada-US corporate reorganisations, Canadian investment in the US, US investment in Canada and cross-border estate planning.

Joel has been involved extensively in writing and presenting articles on international, federal and provincial income tax, GST and retail sales tax issues. Joel is a member of a number of different tax committees including a joint Canada Revenue Agency (CRA)/Canadian Bar Association committee in the pacific region of the CRA.

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

Formerly Fraser Milner Casgrain

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 LLP tax partner based in Toronto. He has 27 years of public accounting experience, including 24 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, Deloitte Touche Tohmatsu.

Rob is a former member of the faculty of the Canadian 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 Guides to the World's Leading Transfer Pricing Advisers and the World's Leading Tax Advisers.

Rob's tax and transfer pricing experience includes planning and competent authority/advance pricing agreement engagements, dealing with the Canada Revenue Agency 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.

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

181 Bay Street

Bay Wellington Tower - Brookfield Place, Suite 1400

Toronto, Ontario

Canada

Tel: +1 416 7758830

Email: crand@deloitte.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, 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 to 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 (LL.M. 1986) and McGill University (LL.B. 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.

250 Howe Street, Suite 700

Vancouver, BC V6C 3S7

Canada

Tel: +1 (604) 806 7244

Email: john.saunders@ca.pwc.com

Website: pwc.com/taxcontroversy

John is a lawyer with more than 20 years of experience in tax litigation and dispute resolution with the Canada Revenue Agency (CRA).

He has negotiated significant reassessment concessions with the CRA and successfully represented clients in the Tax Court, the Trial Division of the Federal Court, the Federal Court of Appeal and the Supreme Court of Canada.

John has been recognised in surveys of his peers as a leading tax specialist by International Tax Review's Tax Controversy Leaders Guide, L' Expert and Martindale-Hubbell.

He has authored numerous articles for the Canadian Tax Journal and delivered published papers at the British Columbia Tax Conference and the National Conference of the Canadian Tax Foundation.

77 King Street West

Suite 400

Toronto, ON M5K 0A1

Canada

Tel: +1 416 863 4761

Fax: +1 416 863 4592

Email: david.spiro@dentons.com

Website: www.dentons.com

David Spiro acts for domestic and international business enterprises on the resolution of income tax controversies and commodity tax disputes. He advises clients on the management of Canadian tax audits and pursues objections and appeals with federal and provincial tax authorities across a wide range of issues.

David has appeared frequently before the Tax Court of Canada and the Federal Court of Appeal and acted as counsel on the first GST appeal heard by the Supreme Court of Canada. He also assists taxpayers in preparing and filing large voluntary disclosure applications and applications for taxpayer relief and has settled significant disputes with the tax authorities on a favourable basis at the pre-assessment, objection and trial stage.

David is recognised for his expertise in tax litigation by Chambers Global 2013: The World's Leading Lawyers for Business, International Tax Review's World Tax 2013, The 2013 Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada, PLC Which lawyer?, PLC Tax on Transactions multi-jurisdictional guide 2012, Legalease Limited's Tax Directors Handbook 2012 and The 2012 Lexpert Guide to the Leading US/Canada Cross-Border Litigation Lawyers in Canada. David has also achieved an AV Peer Review Rating from Martindale-Hubbell.

David is a member of the Tax Court Bench and Bar Committee, the editorial board of Tax Litigation, The Advocates' Society, Canadian Tax Foundation, International Fiscal Association, Canadian Bar Association and American Bar Association. He is a past co-chair of the Toronto Centre Canada Revenue Agency & Professionals Group and founding chair of the tax litigation skills certificate programme at The Advocates' Society. David is a former member of the Minister's Advisory Committee on Appointments for the Tax Court of Canada and is the recipient of a University of Toronto Arbor Award.

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

Formerly Fraser Milner Casgrain

850 - 2nd Street SW, Suite 700

Calgary, AL T2P 0R8

Canada

Tel: +1 403 2670503

Email: curstewart@deloitte.ca

Curtis Stewart is a senior tax litigator in the Calgary office of Deloitte Tax Law LLP, 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's Guide to Leading Lawyers in Canada and 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's experience also includes the GST and commodity tax areas.

Curtis is 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.

99 Bank Street

Suite 800

Ottawa, ON K1P 1E4

Canada

Tel: +1 613 782 2973

Email: marc.vanasse@ca.pwc.com

Website: pwc.com/taxcontroversy

Marc Vanasse is the leader of PwC's Canadian tax controversy and dispute resolution team and a partner in the Canadian national tax services group.

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 served as a member of the CRA's GAAR Committee (1999 – 2011), a member of the Technical Committee on Business Taxation (the Mintz Committee) and a member of the CRA's Taxable Benefits Committee.

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.