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With the recent release of the McKesson decision, Canadian courts have now ruled on four major transfer pricing cases that have arguably altered the meaning of the arm’s length principle. Standing in contrast with the well-established U.S. and global legal framework, the trends in Canadian law may indicate a more significant evolution of the principle.
In a new 90-minute program from Bloomberg BNA, four leading Canadian and U.S. tax litigators and economists will discuss:
• The impact of the latest Canadian and key U.S. transfer pricing cases including the GlaxoSmithKline, General Electric Capital, Alberta Printed Circuits, and McKesson decisions
• Outline the relevant legislative framework in each country
• Compare and contrast how the courts are interpreting the arm's length principle in each country
• Recognize the trends in Canadian law and assess that impact on cases pending in Canadian and U.S. courts
• Navigate through the emerging differences in the meaning of Arms-Length principles as applied to the transfer pricing rules;
• Evaluate the different perspectives on legislative and judicial trends in North America that could impact strategic and global business decisions; and
• Analyze the key cases emanating from Canada and the U.S. that are shaping the meaning of "arm’s length."
Jacques Bernier, is a Partner and Leader, Canadian Tax Litigation Practice with over 30 years of Canadian tax litigation experience based in Baker & McKenzie's Toronto office. Mr. Bernier assists his clients in resolving their Canadian tax controversies and litigating them before the courts. He is recognized as a leading practitioner in Chambers Global: The World's Leading Lawyers for Business, Euromoney's Guide to the World's Leading Transfer Pricing Advisors and is repeatedly recommended for corporate tax litigation by the Canadian Legal Lexpert Directory. According to Chambers Global, Mr. Bernier has a "good presence in court" and is "very determined, pragmatic and knowledgeable.” Mr. Bernier concentrates on tax litigation and representations to the Canadian tax authorities at the federal and provincial levels on a wide range of tax controversies. His most recent involvements include anti-avoidance, transfer pricing, FAPI, HST and provincial sales tax, SR&ED tax incentives, independent contractor vs. employee status issues, taxable benefits, voluntary disclosures, taxpayer relief and judicial review. He represents both domestic and multinational enterprises, professional firms and select individuals.
Philip Carmichael, is a Partner and U.S.-based Economist with 20 years of transfer pricing experience based in Baker & McKenzie's New York office. He has advised several US-based companies on global transfer pricing including transfer pricing analysis, planning, documentation and dispute resolution. He has also coordinated and prepared documentation to serve the needs of tax authorities across different jurisdictions. In transfer pricing disputes, he has assisted in the preparation of economic analyses and responses to information requests, as well as advised on strategy. Prior to joining Baker & McKenzie, Phil was a principal in the economic and valuation services practice of KPMG LLP.
Thomas Linguanti, is a Partner of Baker & McKenzie's North American Tax Practice Group, with 24 years of experience in litigating U.S. tax disputes, and is based in the Firm's Chicago office. Mr. Linguanti's extensive tax experience began as a trial and, then, appellate attorney with the US Department of Justice, Tax Division. Mr. Linguanti's practice continues to focus on tax controversies and litigation and includes counseling clients during audit, administrative appeals, and alternative dispute resolution proceedings, as well as in courts throughout the United States.
Chris Raybould, MA, CFA, is a Partner, Economist, and Leader of the Canadian Transfer Pricing Practice with over 15 years of experience advising on Canadian transfer pricing with the Toronto office of Baker & McKenzie. Mr. Raybould’s practice focuses on transfer pricing dispute resolution and advisory work in a variety of capacities. Mr. Raybould delivers many types of transfer pricing projects including risk identification and assessment, planning studies, and compliance studies. He also advises and assists companies with the transfer pricing aspects of business conversions and restructurings, acquisition due diligence and integration, audit defence representation, appeals, competent authority requests, Transfer Pricing Review Committee representation, and negotiating advance pricing arrangements. Mr. Raybould has extensive experience in a number of industry sectors including manufacturing, particularly automotive, consumer business with emphasis on franchising, technology, and commodity-based businesses such as oil and gas and forestry. The transactions addressed varied from financial transactions, transfers of tangible goods, provision of services, licensing of technology, and franchising, to complex restructurings and redesigns of business and transfer pricing models as well as transaction flows. Mr. Raybould is also an author on transfer pricing issues and frequent speaker.
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