FOREIGN AFFILIATES

Making sense of the Foreign Accrual Property Income (FAPI) rules
Charlie Webster

Impact of tax treaties
John G. Lorito

Structuring and reorganization of foreign affiliates
Angelo Nikolakakis

Tax compliance and dispute resolution issues arising in the foreign affiliate context
Edward Rowe

Financing foreign affiliates
Angelo Nikolakakis

Intellectual Property ("IP") considerations for foreign affiliates
Derrick A. Novis

Tax-effective strategies for repatriating profits and capital
Robert McCullogh

Angelo Nikolakakis is a partner in the tax group in the Montreal office of Couzin Taylor LLP, and is a Limited Partner of Ernst & Young LLP. Angelo is a member of the Bars of Ontario, Quebec and New York State, and a sessional lecturer from time to time on Tax Policy and International Taxation at the Faculty of Law, McGill University, in Montreal. His practice focuses on income tax planning, advising corporate clients on federal international income tax matters. Angelo is the author of numerous professional articles and other publications, including the Taxation of Foreign Affiliates, as well as a frequent speaker on various topics in corporate and international taxation.

Tina Korovilas
Couzin Taylor LLP

Tina Korovilas is an associate with Couzin Taylor LLP, allied with Ernst & Young LLP, in Toronto. Tina practices in the area of federal corporate income tax, focusing on cross-border mergers and acquisitions, reorganizations and structured finance. She has contributed articles to several tax publications, including the Tax Management International Forum and International Tax Review. Tina is a member of the Canadian Bar Association, Canadian Tax Foundation and International Fiscal Association.

John G. Lorito
Stikeman Elliott LLP

John Lorito is a partner in the Tax Group in the Toronto office of Stikeman Elliott LLP. He conducts a general income tax practice with particular emphasis on the areas of corporate reorganizations, mergers and acquisitions, investment funds, income trusts and international tax planning. He has advised on tax issues relating to cross-border and domestic financial products and real estate investments and issues relating to Canadian residents' investments in non-resident trusts and foreign investment entities. He has also acted as counsel on federal and provincial income tax appeals. He is recognized by Lexpert, the Canadian legal directory, as a "repeatedly recommended" practitioner in the Corporate Tax, Investment Funds & Asset Management and the Derivative Instruments sectors. He appears as a "leading individual" in the Tax practice area in Chambers & Partners' The World's Leading Lawyers 2005, and is listed in the 2006 edition of The Best Lawyers in Canada in the area of Tax Law.

Robert McCullogh, CA, is a Senior Tax Advisor in the International Tax Services group of the Montreal office of Deloitte & Touche. He has a Bachelor of Commerce degree and a Graduate Diploma in Public Accountancy from McGill University. He specializes in international tax and has experience in structuring mergers and acquisitions, corporate financing and corporate reorganizations involving Canadian multinational corporations. Since 2003, he has been a tutor for the CICA Advanced International Tax Course. He taught the international tax course for the Graduate Diploma in Taxation program of the Centre for Continuing Education at McGill University from 1995 to 2004.

Derrick A. Novis
KPMG LLP

Derrick A. Novis is a Partner, Taxation Services, Canada at KPMG LLP. He is a Chartered Accountant, B.Com (Hons.). Derrick's practice encompasses a significant multinational high tech companies. Derrick has extensive experience with respect to due diligence engagements for high tech companies. Derrick is a member of the Canadian Tax Foundation and the International Fiscal Association and a former member of the Tax Planning Panel of the Board of Trade of Metropolitan Toronto and the Canada Revenue Agency Appeals Committee. Derrick has co-authored a number of books and publications on tax matters. His presentations and papers include "Getting Something Back From the Government: Taking Advantage of R&D Tax Credits", published by the Ontario Institute Conference; "Taxation of U.S. Business Operations: A U.S. and Canadian Perspective".

Edward Rowe is a Partner in the Taxation Group based out of the Calgary office of Blake, Cassels & Graydon LLP. He provides tax advice on Canadian and cross-border mergers and acquisitions, corporate reorganizations and financing transactions. He has particular experience with resource taxation matters and the structuring of energy-related investments in Canada and overseas. In 2003, he served on Executive Interchange as a special advisor to the Tax Policy Branch, Tax Legislation Division of the Department of Finance. He has been involved in tax litigation before all levels of court and in the settlement of numerous tax disputes with the Audit and Appeals Divisions of the Canada Revenue Agency.

Charlie Webster, CA, is a partner in the International Tax Services group of Ernst & Young LLP in Toronto. His area of practice focuses primarily on outbound investment from Canada and on inbound investment to Canada. His experience with Canadian multinationals includes structuring international holdings, crossborder financing, acquisitions, divestitures, reorganizations and liquidations of foreign affiliates, tax effective earnings repatriation to Canada and foreign affiliate surplus account analysis. He is a member of the Canadian Tax Foundation and International Fiscal Association.

Penny Woolford is a partner in charge of KPMG's International Corporate Tax Services Group in the GTA. She has over 19 years tax experience specializing in corporate tax with an emphasis on international tax, corporate reorganizations, financings and mergers and acquisitions. Penny has been involved in the subcommittee for the CBA/CICA joint committee making representations to the Department of Finance in respect of the foreign affiliate technical changes. She is also a frequent tutor at the CICA Advanced Tax Course on International Tax. She has written numerous articles and presented on international tax matters for IFA, the Canadian Tax Foundation, and Federated Press.