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Transfer Pricing & Tax Aspects of IP Offshoring
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Transfer Pricing & Tax Aspects of IP Offshoring

Toronto Chapter Meeting

When: Thursday, April 7, 2016
12:00 pm - 2:00 pm
Where: Richter Toronto
181 Bay St., Suite 3320
Bay Wellington Tower
Toronto, Ontario  M5J 2T3
Contact: Phil Goldbach

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David Hogan, Partner, Richter
Irina Oks, Principal, Richter 

This presentation discusses the key transfer pricing and tax considerations in connection with the offshoring of intellectual property. Potential benefits and risks of having IP holding companies in foreign jurisdictions are addressed given today’s complex and fast-changing international tax landscape. The presentation illustrates a common IP holding structure (the “Double Irish” structure) used by some of the largest U.S. multinationals, including Apple and Google. Finally, recent OECD developments in respect of transfer pricing aspects of intangibles, as well as jurisprudence related to IP structures is discussed.

Early in USD
LES Member: $20
Non-Member: $30

By cheque onsite in CDN
LES Member: $30
Non-Member: $40

Lunch will be provided.


With a wealth of experience in cross-border tax planning and specialized knowledge in his repertoire, David Hogan helps clients enhance shareholder value through an integrated approach to tax, finance, and operations. He began his career as an economist at the Canadian central bank before entering public accounting as a tax consultant. He led Fujifilm Canada’s value improvement process with responsibilities for tax, finance and accounting before returning to public accounting as the Chief Economist – Transfer Pricing at a Big-4 accounting firm in Canada. David has a Masters in Economics and a CPA, CMA designation, has served on Canada Revenue Agency’s Large Business Advisory Committee, and is a frequent speaker on matters of cross-border taxation from a Canadian perspective.


Irina Oks is a Principal at Richter, with extensive experience in transfer pricing and international tax advisory. She analyzes inter-company pricing policies, and provides audit defense support to multinational corporations in various industries, including the apparel, pharmaceutical, real estate and service industries. Irina develops financial models to assess companies’ global tax position and provides them with recommendations to achieve their business objectives in the most tax-efficient manner. Irina has a Masters in Economics, and is a graduate of the CPA Canada In-Depth Tax Program. She is also fluent in English, Russian, Hebrew and French.