About the speakers. Ed Kroft, QC, Blake, Cassels & Graydon LLP

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1 Ed Kroft, QC, Blake, Cassels & Graydon LLP Ed leads the Tax Controversy & Litigation Group. He regularly appears before the Supreme Court of Canada, the Tax Court of Canada, the Federal Court of Canada, the Federal Court of Appeal and the Supreme Court of British Columbia, where he represents clients in tax disputes involving Canada Revenue Agency and other tax authorities. He also negotiates major transfer pricing disputes and continues to be involved in a number of tax cases for major Canadian and foreign corporations. Ed was a member of the Rules Committee of the Tax Court of Canada for 20 years and was a member of the CRA Liaison Committee of the Canadian Bar Association (CBA) (B.C. Tax Section) for many years as well. He is a former governor of the Canadian Tax Foundation and a former chairperson for the Tax Subsection of the British Columbia branch of the CBA. The Honourable David E. Graham, Tax Court of Canada, Ottawa Born in Montreal, Quebec, and raised in Vancouver, British Columbia. Educated at the Richard Ivey School of Business at the University of Western Ontario (1992) and the University of British Columbia (LL.B. 1996). Called to the bar in British Columbia (1997). Associate ( ) and partner ( ) at Koffman Kalef LLP. At the time of his appointment, substantially all of his practice involved income tax and GST litigation. Prior to his appointment, held various positions with the Tax Law Subsection of the British Columbia Branch of the CBA, including chair (2010 and 2011), and was a presenter at numerous Canadian Tax Foundation events. Appointed judge of the Tax Court of Canada on October 5, 2012.

2 Arnold Bornstein, Department of Justice, Toronto Arnold Bornstein is a General Counsel with the Tax Law Services Division of the Department of Justice in Toronto. He is called to the bars of Ontario and Quebec. He has an LL.B and a B.C.L from McGill University. Nathalie Goyette, Wilson & Partners LLP, Montréal Nathalie Goyette is a Partner responsible for tax litigation and for the Montreal Office of Wilson & Partners, a law firm affiliated with PricewaterhouseCoopers LLP/s.r.l./s.e.n.c.r.l. Nathalie has over 20 years experience dispute resolution relating to audits and appeals from Federal and Provincial Competent Authorities. She helps her clients manage all aspects relating to tax audits and represents them in court. Prior to her joining Wilson & Partners, Nathalie was a Partner in a major Canadian law firm, and previously, a Senior Counsel at the Tax Litigation Directorate at Justice Canada. Nathalie has a Civil Law Licence (LL.L.) from the University of Ottawa, a Bachelor of Laws (LL.B.) from the Dalhousie University and her Masters in Taxation (M.Tax) from the University of Sherbrooke. Nathalie issued several publications and spoke at several conferences in Canada and abroad. She is a Member of the Tax Rules Committee at the Tax Court of Canada, of the Quebec Tax Bar, of the Canadian Tax Foundation, of the International Fiscal Association and the Association for Financial and Tax Planning. Catherine Letellier de St-Just, Canada Revenue Agency, Ottawa Catherine Letellier de St-Just is the Director General of the Tax and Charities Appeals Directorate in the Appeals Branch since October Catherine began her career with the federal public service in 1996 as counsel for the Department of Justice, Tax Law Services (TLS) Portfolio and litigated tax cases before the Tax Court of Canada and the Federal Courts. She progressively held more responsible positions within the Department of Justice from counsel to Deputy Director-Litigator and Acting Director of the Ottawa Tax Law Services section. In January 2011, she joined the CRA on an exchange program as Director of the GST, International and Financial Division, at the Tax and Charities Appeals Directorate. Catherine is a graduate of the Faculty of Law, Civil Law Section, and of the Faculty of Social Sciences, Political Science and Public Management of the University of Ottawa and is a member of the Quebec bar.

3 Doug Powrie, Teck Resources Ltd., Vancouver Doug Powrie is the Vice President of Tax at Teck Resources. Teck is Canada s largest diversified resource company, committed to responsible mining and mineral development. Teck produces materials essential to the quality of life of people around the world copper, steelmaking coal, zinc and energy. Prior to joining Teck, Doug practiced as a tax lawyer for nearly 25 years. Doug has served as a Senior Rulings Officer with the Canada Revenue Agency and as an adjunct professor at the University of British Columbia Faculty of Law.

4 The Honourable Johanne D'Auray, Tax Court of Canada, Ottawa Justice D Auray was appointed to the Tax Court of Canada, on October 29, Prior to her appointment, she was the Assistant Deputy Minister for the Central Agency Portfolio and special counsel for the Federal Department of Finance. Before joining the Department of Finance, she held the position of Assistant Deputy Attorney General for the Tax Law Services Portfolio at the Federal Department of Justice. She had a lengthy career with the Federal Department of Justice where she held the positions of tax litigator, National GST Coordinator, Ottawa Tax Law Services Director, Quebec Regional Office Director and National Tax Avoidance Coordinator. Before obtaining her law degree from the University of Ottawa, she obtained a B.Com with a specialization in accounting, also from the University of Ottawa. She was admitted to the Quebec bar in The Honourable Brent Paris, Tax Court of Canada, Ottawa Brent Paris is a Judge of the Tax Court of Canada (appointed 2002). Formerly Director/General Counsel, Tax Law Services, BC and Yukon Regional Office, Department of Justice. LLB University of Ottawa Tom Boddez, Thorsteinssons LLP, Vancouver Tom Boddez is a partner of Thorsteinssons LLP. He has served as the Managing Partner, and also as a Governor of the Canadian Tax Foundation. He received his LL.B. degree from the University of Toronto and his B.Comm. degree from the University of Alberta. He was admitted to the British Columbia Bar in Tom is a member of the Thorsteinssons tax litigation group and is regularly recognized as one of Canada s leaders in the field of tax controversies. Tom s civil litigation practice includes representation of taxpayers in the audit and appeal processes with the Canada Revenue Agency, as well as appeals heard by the Tax Court of Canada, Federal Court, provincial superior courts, the Federal Court of Appeal and the Supreme Court of Canada. Tom also has extensive experience in the area of tax evasion investigations, trials and appeals.

5 Martin Gentile, Department of Justice, Montréal Martin Gentile has been a member of the Quebec Bar since He joined the Québec Regional Office of the Department of Justice in 1991, where he has been representing the CRA before the Tax Court of Canada, the Federal Court, the Federal Court of Appeal and the Superior and Supreme Courts of various provinces ever since. He has been invited on numerous occasions to speak at conferences and training sessions presented by the CRA, the APFF and the CTF. Howard E. Johnson, MBA, FCPA, FCA, FCMA, FCBV, CPA, CFA, ASA, CF, C.Dir, Managing Director, Campbell Valuation Partners Limited, Toronto Howard is a Managing Director at Campbell Valuation Partners Limited ( CVPL ), Canada s longest established independent business valuation firm. He is also a Managing Director at CVPL s sister firm, Veracap M&A International, which is part of a global merger and acquisition advisory organization (M&A International) comprising over 600 professionals in 42 countries. Howard currently serves as the President of M&A International. Howard advises business owners, executives and corporate boards on acquisitions, divestitures, financing and business valuation. He is the author of eight books on the subjects of business valuation and corporate finance, which are published by the Chartered Professional Accountants of Canada and Thomson-Carswell. This includes the book entitled Business Valuation (CPA Canada, 2013), which is the principal text used by the Canadian Institute of Chartered Business Valuators in its CBV accreditation program. Howard has acted as an expert witness for both taxpayers and the Crown on numerous occasions. He was the Crown s expert in well-known cases such as CIT, McKesson, Garron, and Marechaux.

6 The Honourable C. Michael Ryer, Federal Court of Appeal, Ottawa Mr. Justice Ryer received a Bachelor of Arts in 1970 and a Bachelor of Laws in 1974, both from the University of Saskatchewan. He received a Master of Laws from the University of Toronto in 1979 and was admitted to the Bar of Saskatchewan in 1975 and to the Bar of Alberta in Mr. Justice Ryer had been senior legal counsel with Deloitte Tax Law LLP in Calgary since From October 2006 to December 2009, he served as a judge of the Federal Court of Appeal. Prior to 2006, he practised income tax law with Bennett Jones LLP, with an emphasis on corporate, resource and international taxation. He was appointed Judge of the Federal Court of Appeal on December 12, The Honourable Eric A. Bowie, Formerly of the Tax Court of Canada, Ottawa Eric Bowie attended UNB Law School as a Sir James Dunn Scholar, graduating in He was called to the Ontario Bar in After spending a year as Law Clerk to the Honourable G. A. Gale, C.J.O., he joined the Federal Department of Justice as a junior tax litigator in In 1976 he became the national Director of Tax Litigation. Over the next 20 years he held various positions in the Department of Justice, including Chief General Counsel, Assistant Deputy Attorney General for Civil Litigation, and Associate Deputy Minister of Justice for Litigation and Regional Operations. He was appointed Queen s Counsel in In 2011 he was appointed a Judge of the Tax Court of Canada. He retired from the Court in 2011.

7 Elizabeth Chasson, Department of Justice, Toronto Elizabeth Chasson is General Counsel in the Tax Law Services Section of the Department of Justice, Ontario Regional Office. Liz attended Osgoode Hall Law School and was called to the Bar of Ontario in Ken Skingle, QC, Felesky Flynn LLP, Calgary Ken has been a lawyer with Felesky Flynn LLP (Calgary office) since 1988, a partner since 1996, co-managing partner since 2008 and was appointed Queen s Counsel in His practice focuses on tax litigation and tax dispute resolution, and he has appeared before the Supreme Court of Canada, the Tax Court of Canada, the Federal Court of Appeal, the Alberta Court of Queen s Bench and the Alberta Court of Appeal representing taxpayers in appeals of tax reassessments. Ken also has extensive experience in the areas of corporate income tax planning, including reorganizations of public and private business enterprises, and personal income tax planning. Ken has been a speaker and panel participant at past Canadian Tax Foundation conferences including the 2012 National Conference, the 2012 Tax Dispute Resolution Compliance and Administration in Canada Conference and several past Prairie Provinces Tax Conferences, and he has made presentations on a variety of tax matters to numerous other professional groups including the Canadian Petroleum Tax Society, the Tax Executives Institute, Calgary Chapter, the Institute of Chartered Accountants of Alberta, the Association of General Counsel of Alberta, and the Canadian Bar Association, Alberta and Saskatchewan Branches. Ken served as a member of the Advisory Committee on Judicial Appointments for the Tax Court of Canada from 2009 to Educational History: Bachelor of Laws (LL.B) (with distinction), University of Saskatchewan, 1987 Bachelor of Commerce (B.Comm) (with great distinction), University of Saskatchewan, 1983 Anne-Marie Lévesque, Canada Revenue Agency, Ottawa Anne-Marie is the Assistant Commissioner of the Appeals Branch at the Canada Revenue Agency. Anne-Marie is a lawyer and prior to joining the CRA, worked with the federal Department of Justice as tax litigator and as legal advisor to deputy ministers and ministers in various economic portfolios.

8 The Honourable Campbell J. Miller, Tax Court of Canada, Ottawa Campbell, much to his surprise or perhaps to his misconception of time, has been on the Bench of the Tax Court of Canada for over fourteen years. Prior to that he practised law for twenty four years with the firm of Bishop and McKenzie in Edmonton, Alberta, enjoying a small business practice with an emphasis on tax and estate planning. Not content to simply practise law he put his undergraduate degree in business administration to good use by serving as Managing Partner for almost five years. After ten years in the practice he returned to school to obtain an LLM from Cambridge. Armed thus, he had a crack at teaching tax as a sessional lecturer both in the Law School and MBA program at University of Alberta, quickly appreciating that teaching requires a different skill set than practising, and, as it turns out, judging. Throughout his career Campbell has enjoyed volunteering on many fronts, to a large extent in the healthcare industry, culminating in serving as the first Chair of the Edmonton Regional Health Authority, at that time the largest health care provider in Canada, and subsequently as the Chair of the Provincial Health Ethics Network of Alberta. He has travelled extensively: canoeing across northern Canada, hiking in Peru, driving a VW van across the Sahara desert and into central Africa, sojourning recently in Paris for four months, backpacking throughout southeast Asia for three months with our two then young sons in tow, sailing up the Yangtze, exploring major cities of the world throughout the U.S, Europe, China, Russia, Japan, India... Clearly passionate about travel but also passionate about judging, especially on a court that affords the opportunity to cross the country coast to coast to coast hearing tax tales (not all tall) from individuals and industry that weave a remarkable tapestry of Canadian life and the interplay between government and taxpayer. Clifford Rand, Deloitte Tax Law LLP, Toronto Cliff Rand is the National Managing Partner of Deloitte Tax Law LLP, a national law firm specializing in tax law with offices in Toronto, Montreal, Calgary and Vancouver. Cliff practices exclusively in the area of tax controversy and tax litigation. He has frequently represented taxpayers in tax appeals to the Tax Court and appellate courts, as well as in judicial review proceedings before the Federal Court. He has a B.A. and a law degree from McGill University, a master s of law degree in tax from York University s Osgoode Hall Law School, and for a few years in the 1980s was a law professor at the University of Windsor.

9 The Honourable Randall S. Bocock, Tax Court of Canada, Ottawa Educated at McMaster University (B.A. 1982) and University of Ottawa (LLB/J.D. 1985). Called to the Bar of Ontario in 1987: Associate (1987) and Partner (1990), Evans, Philp LLP, Hamilton ( ), Department Head of business and property law and Chair of the Management Committee ( ). Prior to appointment to the Tax Court of Canada: Chair of the County & District Law Presidents Association, member of the Hamilton Law Association, member of the Canadian Association of University Solicitors, President of the McMaster University Alumni Association, executive member of the National Council of Bar Presidents (ABA Bar Leaders Group) and Board of Directors ( ) of the Lawyers Professional Indemnity Company (LawPro); Founding Director and Secretary of the Haven of the Homeless Child (Child Haven), Board Member of the Hamilton Shelter Health Network and Board of Directors of the McMaster University Foundation. Appointed Judge of the Tax Court of Canada on September 30, 2011: Chair of the Court s Education Committee, member of the National Judges Committee on Information Technology and Information Management and member of the Permanent Programme Committee for the International Association of Tax Judges. Patricia Lee, Department of Justice, Toronto Patricia Lee, Senior General Counsel, Tax Law Services, Department of Justice, Ontario Regional Office Department of Justice, 1981 present: Counsel in the Tax Law Services group, Toronto office, Ontario Regional office, appeared in the Tax Court of Canada, Federal Court of Appeal and the Supreme Court of Canada in litigation involving the Crown and the Minister of National Revenue Representative of Attorney General of Canada, Rules Committee, Tax Court of Canada, Have participated as panel member in conferences presented by the CTF and the CRA Toronto Professionals Group Seminar Member of L.S.U.C., L.L.B. University of Toronto, 1979, B.A. University of Toronto, 1973

10 Martha MacDonald, Osler, Hoskin & Harcourt LLP, Toronto Martha MacDonald is a partner in the tax department at Osler Hoskin & Harcourt LLP. She practises tax litigation before the Tax Court of Canada, Federal Court of Appeal and Ontario Superior Court of Justice, as well as dispute resolution with the Canada Revenue Agency. Martha has been involved with tax issues including transfer pricing, tax avoidance, foreign tax credits, residence for tax purposes, taxable employment benefits, and goods and services tax, in addition to a range of administrative and procedural matters specific to the tax area. Recent Matters: Burlington Resources Finance Company and Conoco Funding Company v. Canada, 2015 TCC 71 motion to compel Crown to answer questions posed on discovery in two transfer pricing cases Canada (National Revenue) v. Conocophillips Canada Resources Corp, 2014 FCA 297 application for judicial review concerning refusal to correct a protective assessment following a test case Minister of National Revenue v. Sifto Canada Corp, 2014 FCA 140 refusal to strike an application for judicial review relating to transfer pricing penalties General Motors of Canada Limited et al v. Minister of National Revenue, 2013 FC 1219 and Szymczyk v. Canada, 2014 TCC 380 Tax Court appeal and Federal Court judicial review concerning retroactive change in method for determining taxable benefits