Michelle is the Deputy Business Unit leader of the Calgary tax practice and a Partner within KPMG’s Global Transfer Pricing Services practice in Calgary. Since 2001 Michelle has been helping clients navigate the rapidly evolving global transfer pricing landscape. Michelle is known for her practical and responsive approach with her clients. She helps a wide range of clients, from large public companies to private enterprises, plan and implement tax efficient and operationally appropriate transfer pricing structures. Michelle’s areas of focus also include tax authority dispute resolution and advance pricing arrangements to help her clients achieve tax certainty. Michelle’s clients range across a variety of industries including energy and natural resources, engineering and construction, technology, manufacturing, and consumer products.
Professional and industry experience
Design, implementation, and documentation of global transfer pricing structures including global value chain analyses, to support a variety of intercompany transactions including tangible product flows, licensing of intangibles, energy trading, asset leasing, financial transactions, and the provision of corporate and various types of technical services.
Canada Revenue Agency dispute resolution including both mutual agreement procedures and advance pricing arrangements for an array of transactions, such as licensing of intangibles, tangible goods pricing, financial transactions, and the provision of corporate and technical services.
Design and implementation of complex corporate cost allocation transfer pricing models for large multinational corporations.
Attribution of profits to permanent establishments and related supporting transfer pricing documentation.
Chartered Accountant, Canadian Institute of Chartered Accountants, 2000
Bachelor of Commerce Degree (First Class Standing), Accounting, University of Alberta, 1997
CICA In-depth Taxation, 2002
Former director and current member, Canadian Petroleum Tax Society
Member, Canadian Tax Foundation