David has 21 years of tax experience, many of which were focused on large Canadian multinationals and their international operations.
He was previously a tax consultant with OMERS, one of Canada’s largest pension funds where he assisted in managing overall enterprise tax risk, tax department composition and design, and assisted OMERS deal teams in assessing multinational investments from an international tax perspective.
David’s primary area of focus is international tax planning and compliance which includes assisting clients implement and defend their tax structures before tax authorities. He has extensive experience in dealing with the Canadian taxation of cross-border distributions, mergers and acquisitions and Canadian inbound financing. More specifically, he helped his clients deal with the following:
- Design and implementation of other international financing structures from a Canadian outbound financing perspective including tower structures and other treaty-based based financing structures for financial institutions and other companies
- Monitoring foreign affiliate tax exposures in the foreign groups of Canadian based multinationals to minimize tax exposures in Canada.
- Review of reorganizations in foreign affiliates of Canadian based multinationals to ensure the reorganization does not trigger any Canadian tax exposures in Canada. Liaise with foreign tax advisors and legal counsel to modify as required.
- Review and design of foreign based multinationals in structuring and operating their Canadian operations. This includes ensuring the multinationals can repatriate Canadian earnings in the most efficient manner possible.
- Review, analysis and computation of the tax retained earnings balances of foreign subsidiaries of Canadian multinationals (“surplus”) to assist them in planning the repatriation of those profits back to Canada.
David is a CPA and has a Bachelors of Commerce from the University of Guelph.