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responsible for Price Waterhouse’s review and recommendation.
Bruce Thorpe (Mr. Thorpe) was the senior manager assigned to
Price Waterhouse’s review and recommendation. Dale Bond (Mr.
Bond) was a senior associate assigned to Price Waterhouse’s
review and recommendation and worked under the supervision of Mr.
Thorpe. Douglas Saunders (Mr. Saunders), who worked in Price
Waterhouse’s office in Mississauga, Ontario (Mississauga
office),5 assisted Mr. Bond in Price Waterhouse’s review and
recommendation. Mr. Saunders continued to provide assistance in
Price Waterhouse’s review and recommendation after he joined
petitioner in March 1993 as vice president and controller.6
As part of Price Waterhouse’s review and recommendation,
Price Waterhouse conducted a study of ITC’s earnings and profits
(ITC’s E&P study). ITC’s E&P study was necessary in order to
5In 1970, Mr. Saunders began working for Price Waterhouse as
a staff assistant in its Toronto office. He became a staff
accountant in 1971, a senior staff accountant in 1973, a supervi-
sor in 1975, a manager in 1977, and a partner in 1980. After
becoming a manager in 1977, Mr. Saunders transferred to Price
Waterhouse’s Mississauga office. During his tenure at Price
Waterhouse, Mr. Saunders was involved in dividend planning for
multinational clients. In that role, Mr. Saunders reviewed
proposed transactions of such clients in order to identify any
potential Canadian tax issues, such as the Canadian nonresident
withholding tax on dividends. Mr. Saunders did not provide any
advice about the United States tax consequences of any such
proposed transactions.
6Mr. Saunders remained as vice president and controller of
petitioner until his retirement. The record does not disclose
the precise date on which Mr. Saunders retired from petitioner.
As of the time of the trial in this case, Mr. Saunders was
working for petitioner under a three-year consulting arrangement.
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