- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011