US-Canada Cross-Border Tax Update

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The US and Canada have the world’s largest bilateral trade relationship.   This results in a significant amount of cross-border tax issues and tax planning opportunities.  In the US-Canada Cross-Border Tax Update, we will provide US and Canadian tax updates on recent tax developments relating to both Canadian investment into the US and US Investment into Canada.  We will summarize current legislative and regulatory developments relating to cross-border tax issues. We will also provide a transfer pricing update specific to the US-Canada marketplace, including APAs, competent authority and controversy matters.

Educational Objectives:
• Current status of certain cross-border planning techniques.
• Current status of the regulatory environment for tax planning in both countries

Who would benefit most from attending this program?
•Tax directors, senior financial officers in companies that have significant US-Canada or Canada-US business operations
•Tax advisors in both the US and Canada that have significant US-Canada cross-border business operations



Mr. Rolph’s practice is focused on helping his clients plan, implement and defend transfer pricing policies that strategically optimize tax-efficient supply chains.  He is also very proficient at pricing intercompany financial transactions.  He has successfully defend taxpayer’s transfer pricing polices under audit, at appeals, and at competent authority.  He has also negotiated unilateral advance pricing arrangements (APAs) and coordinated bi-lateral APAs.  He provides litigation support and expert witness reports to law firms representing clients with transfer pricing matters.

Mr. Rolph was the first economist hired by any of the major accounting firms in Canada to practice exclusively in the area of transfer pricing.  He has been advising multinational companies from a wide cross-section of industries for over 18 years.  He has dealt with Euromoney recognizes Brad as one of Canada’s leading transfer pricing advisers in its 2013 Guide to the World’s Leading Transfer Pricing Advisers.  

His areas of expertise include planning, implementing and documenting intercompany transactions for tangible goods, services and intangibles in a tax-efficient, defendable manner (“TESCM”); building models to price complex financial transactions; resolving audit disputes at the field, appeals and Competent Authority level; negotiating advance pricing arrangements (“APA”); and providing litigation support.

Brad has served companies based in Canada, the United States, England, Ireland, Finland, France, Germany, Sweden, Saudi Arabia and Japan.  He has dealt with issues in the following industries: Aerospace, Mining, Metals and Minerals, Pulp and Paper, Transportation, Heavy Manufacturing, Steel, Utilities, Automotive, Chemical, Pharmaceutical, Food and Beverage, Electronic, Financial Services, Wholesale Trade, Apparel, Consumer Goods and Entertainment.  He also has extensive experience with Japanese trading companies and web-based businesses.

Previously, Mr. Rolph was a Vice President and National Leader of Charles River Associates’ transfer pricing practice in Canada, and an Equity Partner and the Chief Economist of Deloitte’s National Transfer Pricing Group in Canada.

Brad is a frequent speaker and commentator on transfer pricing matters.  He has been published in International Tax Review, Euromoney and Tax Management International.

In addition to an Honours Bachelor of Arts degree in economics from Wilfrid Laurier University and a Masters of Arts degree in economics from Queen’s University, Brad has completed the course work and comprehensive theory exams in economics at the Ph.D. level at York University.


A lawyer by profession, Tina practices in the area of federal international income tax, with particular focus on advising multinationals on international tax matters, including cross-border mergers and acquisitions, reorganizations and structured finance. Her clients have included large financial institutions and public companies in the technology, steel, mining and manufacturing industries. 

Tina brings 18 years of top tier law firm and “Big 4” experience and has a significant international network, having worked in Toronto, New York, London (UK) and Athens (Greece).

Tina has contributed articles on international tax topics to several publications, including Tax Management International Forum and International Tax Review, and lectured at the Federated Press Foreign Affiliate Course for several years.  She has also spoken at the Ontario Tax Conference and the Tax Executive Institute.


Tim has over 11 years of experience in public accounting dealing primarily with corporate tax compliance and consulting as well as ASC 740 computations and analysis for many Grant Thornton and non-Grant Thornton audit clients.  Tim advises many US and non-US multinationals on their international structuring, planning, and compliance. Tim has extensive experience in many corporate technical areas including earnings & profits, reorganizations, and consolidated tax return issues.

Tim works primarily with clients in the technology, medical technology, consumer and industrial products, retail, and transportation areas.

Professional qualifications and memberships
• American Institute of Certified Public Accountants
• Minnesota Society of Certified Public Accountants

• Bachelor of Science Degree in Accounting, University of Minnesota
• Masters of Business Taxation in Accounting, University of Minnesota