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Appendix 1 about the authors Jacques Bernier Baker & McKenzie LLP Jacques Bernier is a partner in Baker & McKenzie LLP’s Toronto office. His practice focuses on litigating and resolving substantial Canadian tax disputes. Jacques has represented corporations and select individuals before tax authorities and tax courts on transfer pricing, anti-avoidance, permanent establishment, scientific research and experimental development, commodity and payroll tax issues, as well as in voluntary disclosure and judicial review processes. He is recognised as a leading practitioner in Chambers Global: The World’s Leading Lawyers for Business and 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. Jacques contributes to various publications and is a frequent speaker at conferences and seminars for tax executives, private practitioners and Canada Revenue Agency personnel. He is a member of the Quebec Bar and the Law Society of Upper Canada. Mark Tonkovich Baker & McKenzie LLP Mark Tonkovich is an associate in Baker & McKenzie LLP’s Toronto office. His practice focuses on resolving tax and related public law disputes with federal and provincial authorities through administrative appeals and in litigation before Canadian courts. Prior to joining Baker & McKenzie, Mark completed a judicial clerkship at the Federal Court of Appeal and was a tax litigator with the Canadian Department of Justice. Clients benefit from his practical insights into tax dispute resolution, formed through his experience on both sides of the courtroom, and his work with judges deciding tax appeals and other federal disputes. Mark studied law as a Lord Beaverbrook Scholar at the University of New Brunswick and he is an active contributor to several publications and legal organisations. He is a member of the Law Society of Upper Canada. 321
Baker & McKenzie LLP Brookfield Place 181 Bay Street, Suite 2100 Toronto Ontario M5J 2T3 Canada Tel: +1 416 863 1221 Fax: +1 416 863 6275 jacques.bernier@bakermckenzie.com mark.tonkovich@bakermckenzie.com www.bakermckenzie.com About the Authors 322
Page 1 and 2: The Tax Disputes and Litigation Rev
Page 3 and 4: The Tax Disputes and Litigation Rev
Page 5 and 6: Publisher Gideon Roberton business
Page 7 and 8: Acknowledgements MORAIS LEITÃO, GA
Page 9 and 10: Contents Chapter 9 INDIA ..........
Page 11 and 12: Editor’s Preface The objective of
Page 13 and 14: Canada agreements. 5 Most of the un
Page 15 and 16: ii Criminal tax prosecutions Canada
Page 17 and 18: Canada by directly substituting its
Page 19 and 20: Canada whether such an infraction a
Page 21 and 22: Canada iii Claimants The general ru
Page 23 and 24: Canada circumstances. 57 Taxpayers
Page 25 and 26: Canada stands at the forefront of t
Page 27 and 28: Canada availability of paper losses
Page 29: Canada as an opportunity to present

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