Dan Rivet is a member of PwC Canada’s Tax Dispute Resolution team based in Ottawa.
Dan spent 20 years at the Canada Revenue Agency (CRA), his last position was CRA Manager – GAAR, Inter-Provincial Tax Avoidance and Technical Support Section. Dan’s career has focused on the area of tax avoidance and aggressive tax planning (ATP). He helped coordinate CRA compliance activities on behalf of its agreeing provinces/territories to ensure their interests were protected in responding to aggressive inter-provincial tax avoidance arrangements through the application of the provincial GAAR. He also helped coordinate the CRA’s identification and detection activities in regards to emerging domestic tax avoidance arrangements as well as the coordination of national projects in regards to mass marketed, unregistered, abusive/aggressive tax avoidance arrangements.
He was a member of the GAAR Committee; the 95(6)(b) Committee; the Transfer Pricing Review Committee (in regards to re-characterization issues); and a regular guest on Federal/Provincial/Territorial Committees. He helped coordinate the development of the CRA’s positions in regards to Retirement Compensation Arrangements and the 10/8 Plan as well as coordinated the CRA’s audit efforts in regards to those issues.
Dan helped provide the Aggressive Tax Planning Division’s views on a variety of issues at GAAR Committee meetings such as reinsurance issues; surplus strips; trust issues; and treaty shopping. He provided training to ATP auditors in a variety of training sessions including the GAAR course; 55(2) issues; and section 85 rollovers. Dan has spoken at numerous APFF conferences and CALU on both domestic and international issues.