Practice

Michael advises U.S. parent companies and U.S. subsidiaries of foreign parents on how to reliably use transfer pricing methods to price transactions between controlled or non-arm’s length parties. He advises clients in a number of capacities – transaction planning, business reorganization and restructuring, strategic policy review and periodic monitoring, compliance with documentation requirements, and during transfer pricing controversy and double tax matters (M.A.P. and A.P.A. procedures).

Clients approach Michael with a question or concern about how a related-party transaction should work, how to manage transfer pricing risk, or how to respond to a tax authority in a dispute. Foreign attorneys seek Michael’s advice on the U.S. transfer pricing aspects of a global transfer pricing policy. Many clients of Big Four accounting firms approach Michael for a second opinion on a transaction characterization or structure, a complex transaction term, or when their advisors run into roadblocks during a transfer pricing examination or controversy.

Michael’s more than 20 years of experience working with advanced transfer pricing matters around the world allow him to quickly see both sides of a transaction and the issues in all jurisdictions, cut through the jargon and detail, deliver highly bespoke advice, analysis and arguments, and explain how it all works in plain English (and French). Where clients would rather not disturb a transfer pricing issue for fear of what they might find, a meeting with Michael (unapologetically E.S.T.J.) can often unexpectedly make things appear less dreadful. He’s an economist who knows the law, tax treaties and administrative procedure, and practices under the assumption that clients operate subject to time and budget constraints.

Qualifications

Education

• B.A. — Queen's University

Languages

• English
• French

Affiliations

Current

• International Fiscal Association
• Canadian Tax Foundation
• International Tax Specialist Group (ITSG)