BorderCrossings with Ernst & Young's transfer pricing and tax professionals

Managing risk in the US and Canada – Ernst & Young's 2013 global transfer pricing survey

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To help you stay informed and able to adapt to an increasingly uncertain and challenging global tax environment, Ernst & Young is pleased to bring you this twenty-fourth installment of BorderCrossings – our monthly webcast series devoted to transfer pricing and related tax issues.

EY’s 2013 global transfer pricing survey reveals companies are placing a higher priority on managing risk associated with transfer pricing, reflecting a need to adjust to heightened scrutiny by tax authorities in both established and emerging economies focusing on transfer pricing. Listen to our experienced panel of former government officials as they discuss the survey results with a focus on the US and Canadian implications of:

  • The increased taxpayer focus on risk management
  • How taxpayers implement and document their transfer pricing policies
  • Key trends in controversy concerns
  • Taxpayers’ experiences in resolving transfer pricing disputes

This program will be of interest to vice presidents/directors of tax/international tax/transfer pricing/customs/global trade, directors of finance, CFOs, international tax managers and tax accountants looking for the latest practical information and guidance to support their global business initiatives. We hope you will be able to join us!


Save the date for the next BorderCrossings webcast:

1:00–2:15 p.m. EDT New York/Toronto; 10:00–11:15 a.m. PDT Los Angeles/Vancouver

  • Thursday, 17 October 2013



David Canale

Ernst & Young LLP (US), Transfer Pricing, International Tax Services

David Canale is a Principal with Ernst & Young LLP and is the Global Ernst & Young organization’s Americas Director, Transfer Pricing Controversy Services. He has over 18 years of experience in transfer pricing. Dave advises both US and foreign-based multinational companies on transfer pricing controversy and risk management, planning and structuring. He assists clients with transfer pricing policies, controversy resolution (including audit dispute resolution), Advance Pricing Agreements, Mutual Agreement Procedures and monitoring tax treaties and competent authority.

Prior to joining Ernst & Young LLP, Dave served with the Internal Revenue Service’s Advance Pricing Agreement Program in the Office of Associate Chief Counsel (International). He was acting branch chief for the program and served as program coordinator for all bilateral Advance Pricing Agreements with Canada. He also developed strategies and coordinated with the US competent authority regarding negotiations with various treaty partners. Dave’s combined IRS and private practice Advance Pricing Agreement and Mutual Agreement Procedure experience includes over 200 cases.

Dave received a B.A., magna cum laude, from the University of Dayton; a J.D. from American University Washington College of Law; and an LL.M. (Taxation) from Georgetown University Law Center.

Fred O’Riordan

Ernst & Young LLP (Canada), Transfer Pricing, International Tax Services

Fred O’Riordan is a National Advisor in the tax practice of Ernst & Young LLP in Canada and also Canadian Leader of EY’s Economics and Analytical Services practice. Fred joined Ernst & Young LLP in February 2010 after a distinguished 33-year career with the federal public service, including over 20 years of experience as a senior executive with the Canada Revenue Agency (CRA) and central agency roles in policy and program evaluation and analysis.

Prior to joining Ernst & Young LLP, Fred was the Assistant Commissioner of Appeals at the Canada Revenue Agency. In this role, he was responsible for dispute resolution for tax assessments and for Canada Pension Plan and Employment Insurance rulings and assessments; assessment litigation before the courts; the CRA’s service complaints and problem resolution programs; and taxpayer relief (legislative discretion over penalty and interest amounts and filing deadlines).

Fred received a B.A. Honours (Economics) from Queen’s University and an M.A. (Economics) from the University of Western Ontario.


Steven Wrappe

Ernst & Young LLP (US), Transfer Pricing, International Tax Services

Steven Wrappe is a principal in Ernst & Young LLP's International Tax Services National Transfer Pricing practice based in Washington, DC. He also provides services in the firm's West Coast Transfer Pricing practice. He is the Americas Director of Advance Pricing Agreements for the Ernst & Young organization.

Steve has served as Chair of the Transfer Pricing Committee of the American Bar Association's Tax Section. He serves on the Board of Advisors of New York University School of Law's International Tax Program and BNA Tax Management (Transfer Pricing). Steve is an adjunct professor at Georgetown University Law Center, the University of Florida School of Law and New York University School of Law. He recently published the third edition of his leading transfer pricing treatise and has written more than 100 articles on transfer pricing topics. Steve speaks with governments and taxpayers on transfer pricing and dispute resolution.