Business Law & Legal Issues Facing Finance Professionals: Is your foreign subsidiary exempt from Canadian tax & transfer pricing? | CPDonline.ca

Business Law and Legal Issues Facing Finance Professionals: Is your foreign subsidiary exempt from Canadian tax & transfer pricing?

Business Law and Legal Issues Facing Finance Professionals: Is your foreign subsidiary exempt from Canadian tax & transfer pricing?

To purchase this video please click “Add to Cart”.

Login to watch this video if you have a subscription. Learn more about subscriptions.
Credits
Substantive: 1.0
Published
2016
Presenter(s)
Joseph Devitt
Jamal Hejazi
Dale Hill
Source
CPDOnline
Provider
CPDOnline.ca
Language
English
Length
65 minutes
Price
$119.00 plus tax
CPDFinance Conference
Includes Handouts
  • Applications of transfer pricing
  • FAPI rules and applications
  • Allocations of costs across foreign subsidiaries. What is allowed from a CRA perspective?
  • Strategies for repatriation of funds

Presenters

Joseph Devitt

Partner, Global Transfer Pricing Services

KPMG Canada

Joe is a Partner with KPMG’s Global Transfer Pricing Practice in Toronto. For over 15 years, Joe has been providing transfer pricing planning, documentation and audit defense services to taxpayers operating across the globe.  

Collaborating with global colleagues in the area of international tax planning and compliance, Joe has assisted taxpayers in establishing defensible transfer pricing structures designed to accomplish global tax objectives while ensuring compliance with local tax laws. 

Joe began his transfer pricing career with KPMG’s Washington DC office in 1997, after which he relocated to Canada to establish KPMG’s Southwestern Ontario transfer pricing practice.  Now part of KPMG’s Toronto office, Joe works with some of Canada’s largest companies in navigating transfer pricing rules domestically and abroad, and resolving transfer pricing disputes.

Jamal Hejazi

Chief Economist

Gowling WLG

Dr. Jamal Hejazi is a senior member of the Gowlings Transfer Pricing and Competent Authority team. Working in conjunction with the Firm's National Tax Practice Group, Jamal helps organizations optimize their global tax position and reduce exposure to unfavorable audit assessments through proper tax planning and implementation strategies. He has been involved in work for a number of industries including automotive, Partner, Tax Services

National Leader, Transfer Pricing & Competent Authority Group

Gowling WLGpharmaceutical, energy, computer software, gaming, manufacturing and services. He also specializes in intangible valuation and has done work for both the technology and biochemical sectors.

Prior to joining Gowlings, Jamal was a senior transfer pricing economist with the Canada Revenue Agency, where he participated in the resolution of a number of transfer pricing issues, including the relief of double taxation on Canadian corporations. He was instrumental in the negotiation of Advanced Pricing Agreements between Canada and foreign tax authorities.

Jamal has also held a faculty position at the University of Windsor, and was a lecturer at both Carleton University and the University of Phoenix. He has also served as an expert witness at the Tax Court of Canada. Complementing his graduate degrees, Jamal has recently earned the Registered Professional Accountant (R.P.A.) designation. He is currently completing his CPA designation in the State of Illinois.

In September 2011, 2013, and 2015, Gowlings was recognized by the International Tax Review as Canada’s Transfer Pricing Firm of the Year.

Dale Hill

Partner, Tax Services

National Leader, Transfer Pricing & Competent Authority Group

Gowling WLG

Dale Hill is a partner in Gowling WLG's Ottawa office and is the national leader of the Gowling

WLG Transfer Pricing and Competent Authority team. Dale works in conjunction with the Firm's National Tax Practice Group to help organizations optimize their global tax position and reduce exposure to unfavourable audit assessments through proper tax planning and implementation strategies. Dale’s specialty is audit defense and dispute resolution, where he has been instrumental in preventing various tax authorities, in North America, Europe and Asia, from raising costly transfer pricing adjustments and penalties on some of the world’s largest multinational companies.

In addition to Dale’s audit defense work, he also overseas the groups transfer pricing documentation and APA practice and is actively involved in providing litigation advice to the Firm clients from a tax perspective. With significant experience dealing with Asian governments and businesses alike, he assists the Firm’s largest Asian clients in optimizing their global operations from a transfer pricing perspective. Dale has worked in a variety of industries including, but not limited to, pharmaceuticals, auto, construction, consumer durables and computer software industries.

Dale’s ability to solve contentious issues draws from his experience vast experience working at the Canada Revenue Agency (“CRA”) at a senior level. Prior to joining Gowling WLG in 2005, Dale was involved in international transfer pricing and tax avoidance with the CRA for 16 years. During his tenure as a senior manager with the CRA's International Tax Directorate, he participated in more than 40 Advanced Pricing Agreements ("APAs") with numerous countries, as well as hundreds of Competent Authority requests relating to international transfer pricing adjustments involving a vast array of issues. He is also experienced in a number of other international tax areas, including interest deductibility, guarantee fees, imputed interest, notional expenses, penalties and appeals. Dale has been successful in resolving a number of controversial audit issues through successful negotiations with various tax authorities in a number of countries around the world.

In 2004, Dale led the development of a national field strategy that defined the working relationship between the CRA's Competent Authority, tax services offices, appeals and head office, with respect to audit adjustments to Canadian taxpayers and audit adjustments initiated by foreign countries.

Dale’s expertise has been recognized many times by various institutions. His group was awarded with Canada Transfer Pricing Firm of the year Award by International Tax Review for the years 2011, 2013, and 2015. His group won the Finance Monthly Transfer Pricing Firm of the Year in 2012. Dale was also named pre-eminent practioner in 2008 in the Guide to the World's Leading Transfer Pricing Advisors publication. He acquired his CPA and CFP designations in 1991 and 1995, respectively, and completed the CICA in-depth tax course in 1999.

Share this Page