Since 1995 Dan has been providing global transfer pricing and dispute resolution services to various multinational enterprises within a broad scope of industries. During this time he has advised clients on matters relating to: transfer pricing planning; risk assessment reviews; documentation; compliance; and, dispute resolution. Dan has also advised clients on a full spectrum of international transactions including: the purchase and sale of tangible products; the development, licensing or sale of intangible assets and intellectual property; the provision of management services; the provision of contract services (manufacturing, R&D and other); cost contribution and/or sharing arrangements; financial transactions; and, cost reimbursements.
From an industry perspective, Dan has significant experience with pharmaceutical, automotive, technology and entertainment companies. From a transaction perspective, he has considerable experience with product pricing, commissions, royalties, cost sharing payments, management fees, services fees, fees for contract manufacturing, fees for contract R&D, loan interest rates and guarantee fees.
Dan draws upon his experiences during his tenure at the Canada Revenue Agency, and previous dispute resolution engagements, to defend transfer pricing policies that are challenged by the Canadian and foreign taxation authorities. He has regularly assisted clients in managing field audits and negotiating with field auditors. Dan has been involved in preparing Notices of Objections for Appeals and submissions in conjunction with Advance Pricing Arrangements.
Dan has been a frequent presenter on transfer pricing issues at numerous external conferences including Infonex, Federated Press, CITE, CGA Canada and CPA Canada.
While Dan has worked at the Canada Revenue Agency and in industry, he has spent most of his 30 plus year taxation career with international firms of Chartered Professional Accountants.
Certified General Accountants Association of Ontario
Canadian Tax Foundation
Professional designations and education
Chartered Professional Accountant, Ontario
Certified General Accountant, Ontario
CPA Canada In-Depth Tax Course, Ontario
Bachelor of Administrative Studies, Ontario