Michelle Levac is a Chartered Accountant, Chartered Business Valuator and Chartered Financial Analyst. She is Chair of Working Party No. 6, dealing with the taxation of Multinational Enterprises, at the Organisation for Economic Co-operation and Development (OECD), the Transfer Pricing Specialist at the Canada Revenue Agency and a Director on the Board of the Canadian Institute of Chartered Business Valuators. Michelle has over 17 years of experience in business equity valuation and transfer pricing, including testifying as an expert witness, negotiating transfer pricing cases with foreign tax authorities and developing international transfer pricing guidance. She has been a speaker and panelist at several national and international conferences.

Lonnie Brist is a member of Ernst & Young LLP's West Sub-Area Transfer Pricing practice in San Jose, California.

Prior to joining Ernst & Young LLP, Lonnie was an assistant professor of economics at the University of Alabama, where he was engaged in applied econometric research of high-technology industries. He practices in the area of firm learning through technological change, changing market shares, firm entry and exit, firm participation and pricing trends. He taught economic courses at the undergraduate and graduate level. As a member of Ernst & Young LLP's Transfer Pricing practice since 1998, Lonnie assists multinational companies with the strategic planning of their intercompany transactions. His areas of practice include transfers of intangible property, trading company activites, manufacturing, distribution, and cost-sharing arrangements. Specific areas of practice relating to intangible property include technology, processes, strategic management, mastheads and call letters.

Lonnie earned his Bachelor of Science in Economics from Montana State University in 1991, and his Master of Arts and PhD in Economics from the University of Oregon in 1996. He has also written a number of articles for various publications.

Alfred Zorzi is a partner with the Canadian transfer pricing practice of Ernst & Young LLP. He has more than 22 years of experience dealing with tax and transfer pricing matters. In the last seventeen years he practiced in transfer pricing, supply chain and cross-border issues. He provides transfer pricing services to numerous Canadian, U.S. and international corporate clients.

Alfred is actively involved in the negotiation of Advanced Pricing Arrangements (APAs) and transfer pricing controversy, including competent authority issues. He is also involved in the design and implementation of large supply chain planning projects. He has extensive, hands-on experience in international transfer pricing for clients in various industries, including pharmaceutical, manufacturing, transportation, energy, distribution and mining. Alfred has established preferred transfer pricing relationships with a number of large multinational companies, and has extensive experience in transfer pricing controversy, including APAs and competent authority issues; tax-effective supply chain management; centralized procurement and sourcing strategies; and planning for intellectual property.

Alfred holds a graduate degree in Accountancy from Concordia University and is a frequent speaker and author of numerous articles on transfer pricing and related matters. He is a Chartered Accountant, as well as a Certified Management Accountant. Alfred is a Governor of the Canadian Tax Foundation. He is also a member of the Association de planification fiscale et financière of Québec.

Fred O'Riordan is a National Advisor in the tax practice of Ernst & Young LLP in Canada. Fred joined Ernst &Young LLP in February 2010 after a distinguished 33-year career with the federal public service. He brings with him over 20 years of experience as a senior executive with the Canada Revenue Agency (CRA).

Prior to joining Ernst & Young LLP, Fred was the Assistant Commissioner of the Appeals Branch at the Canada Revenue Agency. In this role, Fred was responsible for dispute resolution for assessments of income tax, GST, HST, excise tax and for Canada Pension Plan and Employment Insurance rulings and assessments; the settlement and mediation process for income and commodity taxes; assessment litigation before the courts; the CRA's service complaints and problem resolution programs; taxpayer relief (legislative discretion over penalty and interest amounts and filing deadlines); and liaison with the Taxpayers' Ombudsman. He also chaired the CRA's Adverse Decision Committee.

Prior to that, Fred was the Director General of the International and Large Business Directorate where he was the delegated Competent Authority for Canada. In that capacity, he was responsible for the operation of Competent Authority functions under Canada's international tax conventions, including the Mutual Agreement Procedure, Advance Pricing Arrangements and the Exchange of Information. He was also responsible for the CRA's international, large business and tax avoidance audit programs.

Fred also served as the Senior Advisor to the Commissioner, the Director General of the Registered Plans Directorate, the Director of Tax Programs for the Quebec Region and the Director General of the Excise Act Review.

Fred is a member and former councillor of the Canadian branch of the International Fiscal Association and a member of the Canadian Tax Foundation. He has been a frequent speaker and panelist at national and international tax conferences.

Prior to his career at the Canada Revenue Agency, Fred was a Group Chief in the Office of the Comptroller General and the Treasury Board Secretariat.

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