FOREIGN AFFILIATES

Foreign accrual property income
Charlie Webster

Relevance of tax treaties
Angelo Nikolakakis

Tax compliance and dispute resolution in the foreign affiliate context
Edward C. Rowe

Foreign exchange implications
Tina Korovilas

Transfer pricing developments
Patrick Cheung

Financing foreign reorganizations
Angelo Nikolakakis

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 L.P. 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. Angelo also participates as a member in numerous professional associations, including the Canadian Tax Foundation, the International Fiscal Association, the American Bar Association and the International Bar Association.

Charlie Webster, CA
Ernst & Young LLP

Edward C. Rowe
Blake, Cassels & Graydon LLP

Edward Rowe is a Partner in the Taxation Group based out of the Calgary office.

Edward provides tax advice on Canadian and cross-border mergers and acquisitions, corporate reorganizations and financing transactions. Edward has particular experience with resource taxation matters and the structuring of energy-related investments in Canada and overseas. In 2003, Edward served on Executive Interchange as a special advisor to the Tax Policy Branch, Tax Legislation Division of the Department of Finance with respect to the reform of the taxation of resource income, cross-border issues affecting public companies and the taxation of business trusts

Edward also conducts an active tax litigation and dispute resolution practice. 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, including the General Anti-Avoidance Rule ("GAAR") Committee. Significant taxpayer litigation successes in which Edward was involved include:
Imperial Oil Limited v. The Queen 2004 FCA 361, rev'ing 2004 TCC 207 (deduction of foreign exchange loss).
Silicon Graphics Ltd. v. The Queen 2002 FCA 260, rev'ing 2001 DTC 379 (meaning of corporate control).
International Colin Energy Corp. v. The Queen 2002 DTC 2185 (TCC) (deduction of transaction costs).
Canadian Occidental U.S. Petroleum Corp. v. The Queen 2001 DTC 295 (TCC) (financing of foreign affiliate).
CIBC v. The Queen 2000 DTC 6207 (FCA), rev'ing 97 DTC 1362 (TCC) (inventory depreciation allowance).
Shell Canada Limited v. The Queen 1999 DTC 5669 (SCC), rev'ing 98 DTC 6177 (FCA) (interest expense).

Edward has authored a number of articles and conference presentations on domestic and international tax planning and tax litigation, including the development of the general anti-avoidance rule. He is a frequent speaker at the Canadian Petroleum Tax Society and has lectured in international tax at the University of Ottawa Faculty of Law. Prior to joining Blakes, Edward was a tax partner with a global accounting firm.

Areas of Practice:
Taxation
Tax Litigation & Controversy Resolution

Education:
Admitted to the Ontario Bar - 2001
Admitted to the Alberta Bar - 1996
Judicial Clerk to the Honourable Mr. Justice J. Major of the Supreme Court of Canada - 1995
LL.B., The University of Calgary - 1994
B.A. Hons (Latin-Greek), The University of Calgary - 1989

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.

Robert McCullogh, CA
Deloitte & Touche LLP

Robert McCullogh, CA, is a Senior Counsel 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. Mr. McCullogh specializes in international tax and has experience in structuring mergers and acquisitions, corporate financing and corporate reorganizations involving Canadian multinational corporations. Since 2003, Mr. McCullogh has been a tutor for the CICA Advanced International Tax Course. Mr. McCullogh 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. He has also written a number of articles on international tax matters.

Patrick Cheung is a Senior Manager of Ernst & Young LLP's International Transfer Pricing Services practice in Toronto, Canada. Prior to joining Ernst & Young, he worked at the Canada Customs and Revenue Agency in the Corporate Audit and the Appeals Divisions in Toronto. At Ernst & Young, he is involved in performing management fees and cost sharing studies, transfer pricing studies, advance pricing agreements and competent authority proceedings for both foreign and Canadian multinationals involving pricing of goods, services and intangibles with experiences in automotive and other manufacturing, building materials and resource, entertainment and media, pharmaceutical industries and financial institutions. He advises clients on various other international tax issues as well as tax audits and appeals and trade-related issues.