Intercompany Transaction Experts
Intercompany Transaction Experts
IVCi is lead by Tim Dunham who with more than 30 years of valuation experience is responsible for organizing and directing the necessary skills and personnel to provide valuation-related advisory services that include tax planning and tax dispute representation, non-arm’s length transaction documentation, corporate reorganizations, intangible asset migration documentation and resolving shareholder-specific valuation issues. He is the former Regional Team Manager of the Canada Revenue Agency’s Toronto-based Valuation Section with 18 years of CRA valuation experience. At CRA he was responsible for effecting and screening potential valuation referrals, completing and supervising valuation reassessments, critiquing external valuation reports, negotiating tax settlements and reviewing CRA Appeal submissions in relation to hundreds of non-arm’s length transactions for both private companies and domestic and international public corporations.
Subsequent to CRA, he has completed valuation mandates involving intangible asset migrations, withholding tax on taxable Canadian property, reconciliations of public trading price and fair market value, restricted securities and options, debt settlement valuations, analysis of non-arm’s length interest rates on debt, deemed disposition valuations and numerous fairness opinions. He has provided effective and efficient valuation tax planning advice and documentary support for corporate reorganizations, intangible asset migration and estate planning requirements and multinational transfer pricing requirements. Tim has successfully and efficiently represented clients with CRA Audit and Appeals, CRA Penalty Review and Fairness Committees and the Competent Authority Services Directorate.
Tim has delivered Regional Valuation and National Headquarters training to Canada Revenue Agency valuators both during and since his tenure with the federal government. He has provided mediation services and Federal Tax Court expert witness testimony for the Department of Justice and at the Superior Court of Ontario. He is a co-author of the CICBV Legal Casebook and has prepared course material and presented workshop and seminar instruction on business valuation and tax dispute resolution for LexisNexis, The Advocates’ Society, Federated Press, the Department of Justice, the Toronto Chartered Financial Analyst Society, the Chartered Business Valuator Institute and various regional CPA Associations. He has developed training material, lectured and taken part in panel discussions in the areas of Financial Analysis, Business Valuation for Tax Purposes and the implementation and impact of the OECD’s Base Erosion and Profit Shifting Action Plan for Multinational Corporations as part of University of Toronto Rotman Management Exchange Program and Rotman MBA Program. Tim may be contacted at 416.844.4717 or by email at tim@ivci.ca
The IVCi analyst team includes experienced, comprehensively trained and professionally qualified and designated individuals available to deliver client mandates in an insightful, thorough and time-conscious manner. Our analysts have experience in international accounting and advisory firms across a variety of industries involving business and tax planning valuations, tax dispute resolution, IP asset migrations, corporate reorganizations, mergers and acquisitions, commercial and shareholder disputes, and valuation for financial reporting. They have extensive knowledge in the tax-related areas of estate freezes, deemed dispositions, execution of ITA Section 85, and tax shelter reassessments involving CRA's Aggressive Tax Planning Section.
IVCi analysts have extensive transfer pricing experience encompassing a wide range of industries including, oil and gas, mining, manufacturing, distribution, financial services, professional services, pharmaceuticals and consumer goods. They are proficient in developing financial models and cash flow forecasts, performing comparables research, and undertaking risk and financial analysis.
For any enquiries relating to client service, planning and scheduling functions please contact IVCi's office administrator at 416.408.4717 or via email at admin@ivci.ca.
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