Brian J. Arnold

Posting: 100
August 8, 2016

Special Report: A Tribute to Larry Chapman 

During my morning walks with Ned over the past couple of months, I have been thinking about what I should write about in my 100th Report. It couldn’t just be more of the same old crap; it had be something special.  And, as you can see, I have come up with the perfect topic: a tribute to Larry Chapman, the man who, for the past 8 years, has provided us with his monthly weather reports, who had the original idea for these Arnold Reports, and who is retiring from his position at the end of this year.


Larry Chapman has been the CEO and Executive Director of the Canadian Tax Foundation since 2008. Larry has that rare combination of excellent technical knowledge, vision, and superb interpersonal skills that made him a natural leader of the Foundation. His technical tax ability has earned him the respect of everyone in the Canadian tax community, and when he became Executive Director of the Foundation, he maintained his technical expertise and continued to write and speak at Foundation events. His ability to deal with people, from the most senior tax professionals to young practitioners, government officials, international colleagues, and the staff of the Foundation, is extraordinary. I have never heard anyone say a bad word about him.


Larry’s personal attributes are a product of his upbringing. He was raised on a farm in mid-Western Ontario in a very close family, and still prides himself on being able to drive the biggest pieces of farm equipment. Several summers were spent driving a milk tanker truck, collecting milk from dairy farmers all over mid-Western Ontario.


After his commerce degree at the University of Toronto, Larry started working at what was then Price Waterhouse, where he came to the notice of Bob Brown, Bob Dart and David Broadhurst, three giants of the Canadian tax community throughout the 1970s, 1980s and 1990s. They recognized Larry as a potential star, and David Broadhurst, in particular, became his mentor. Eventually, he became the worthy successor to these three giants as PwC’s go-to guy on international tax issues. Larry’s career took a short detour in 1997, when he became Vice President of Taxation at Bacardi, one of his clients, and moved to Bermuda where its headquarters are located; however, he missed being so far away from family and returned to Toronto after only 18 months (probably not enough time away to get nonresident status?).  He returned to PwC as national managing tax partner from 1998 to 2007, and during that time was also co-editor of the International Tax Planning Feature in the Canadian Tax Journal and a frequent speaker at CTF conferences.


I first met Larry in 1994 through the Foundation. Doug Sherbaniuk, the Director at the time, had asked me to prepare a case study dealing with cross-border joint ventures for Larry and David Smith to discuss at the Corporate Management Tax Conference in Toronto. I had worked with David Smith at Davies, Ward & Beck (as it was known at the time) and knew how smart he was, and I knew Larry’s writings on international tax, so I jumped at the prospect. Working with those two, I thought, would give my reputation a real boost, and I could learn a lot.


Then reality set in. I didn’t know much about cross-border joint ventures, and as an academic, I didn’t have a thorough understanding of the issues from a practical perspective. I spent ages researching the topic and preparing the case study in the hope that Larry and David would not find it totally useless. Both being nice guys, they made suggestions for improving the case study without making me feel stupid, and the session was reasonably successful. After I got to know him better, Larry told me that he was intimidated to be presenting with David Smith and me and that he had spent untold hours preparing for the session. If only we had known at the time, we could have provided comfort for one another – and if anyone is wondering, I’m certain that David Smith was not intimidated by either one of us.


I have had excellent relationships with previous Directors of the CTF: Doug Sherbaniuk, Tom McDonnell, Robin MacKnight and Steve Richardson. They supported my research, gave me opportunities to speak at CTF conferences, and also provided personal encouragement for my work.


When Larry became CEO and Executive Director of the Foundation in 2008, I didn’t know him very well, but I put him to the test right away. The Advisory Panel on Canada’s International Tax System was scheduled to report in 2008. I knew that my ideas about our international tax system would be very different from the Advisory Panel’s; as a result, I thought it would be good if I could produce a book on that subject, to be published at the same time as the Advisory Panel’s report was published, in order to provide a different perspective on the issues. The Foundation was the logical (only?) publisher for such a book, but I thought it might be reluctant to publish a book that could be seen as competing with the Advisory Panel’s Report – especially a book whose recommendations for reform would be viewed unfavourably by most tax practitioners.


Obviously, I didn’t know Larry Chapman well enough. From the outset and in spite of considerable opposition, he was supportive of the book as an example of precisely what the Foundation should be doing. I was impressed with his support and his vision of the role of the Foundation in encouraging research and stimulating debate on tax issues. In the interests of full disclosure, I should note that, although Larry did not make support for the international book conditional on my doing a second edition of Timing and Income Taxation, he made it clear at every opportunity that the second edition was a high priority.


After the publication of the international tax book, Larry invited me to be a panelist on international panels at various CTF conferences and I got to know him better. In 2009 I left Goodmans (I had left academe in the mid-1990s) and started describing myself as a tax consultant. At a break during the 2010 IFA Travelling Lectureship, which I presented with Jacques Sasseville, Larry suggested that it would be better if I were presenting as Brian Arnold of the Canadian Tax Foundation. I thought he was joking. (I should have known that this was just part of Larry’s strategy to get a second edition of the Timing book.) However, it didn’t matter because once Larry held out the tantalizing prospect that I could write a regular blog for the CTF website (it was his idea, not mine) I was putty in his hands. Writing the Arnold Report has been my dream job and I owe it all to Larry; I cannot thank him enough.


Larry’s accomplishments since taking over as Executive Director of the Foundation are substantial and far too numerous to detail here. A brief list of some of the more significant accomplishments will give you a sense of Larry’s leadership.   He has guided the Foundation astutely through the financial crisis and its financial position is healthy.  He led the Foundation through the difficult process of deciding whether to introduce a professional tax designation – a process that revealed surprisingly different views between older and younger practitioners, between accountants and lawyers, and between the Foundation and CPA Canada. He supervised the adoption of improvements to TaxFind and a CTF platform for ebooks that makes future CTF publications readily updateable and fully searchable. He has forged strong relationships with the Department of Finance and the CRA (invitational roundtables on the tax policy process and the OECD/G20 BEPS Project are just two examples), with the OECD (senior officials from the OECD have been frequent speakers at CTF conferences in the last 8 years), and with the Canadian Branch of IFA (joint conferences on BEPS have been held for the past 3 years). And, of course, he did get the second edition of the Timing book, which was published last year, as well as several other important publications.


Perhaps Larry’s greatest contribution to the Foundation – and I’m sure the one that he is most proud of – is the incredible group of people he has assembled, the staff of the Foundation who make it work. I cannot mention them all here, but kudos to Debbie Selley, the treasurer, who has recently retired; Roda Ibrahim and Nadia Singh, who make the conferences run like clockwork; Judy Singh, the librarian of unquestionably the finest tax library in Canada; Jane Meagher, the Director of the Quebec office, who is responsible for building up a strong program of activities there; Wayne Adams, formerly of the CRA Rulings Directorate, who does a little bit of everything, including the young practitioners program and the annual mentorship dinner;  Vivien Morgan, the long-time editor of Canadian Tax Highlights, and the editorial team who look after all the CTF publications; and Leslie Barrett, Larry’s personal assistant, who keeps his professional life organized. Larry deserves an enormous amount of credit for putting this team together and ensuring that the activities of the Foundation will continue to flourish after he leaves.


Any tribute to Larry would not be complete without some mention of his charitable activities, his exploits as a triathlete, his love of good wine, and his family. He combines the first two as an organizer of the annual Joe’s Team triathlon on behalf of Princess Margaret Hospital and is also Chair of the St. Joseph’s Health Centre Foundation; until recently, he was chair of the audit committee for Victoria College at the University of Toronto. Larry and I have similar tastes in wine – tart New Zealand Sauvignon Blancs and Brunellos with a bit of age – although we seem to do much more talking about wine than actually drinking the stuff. Larry’s family – his wife Cassie, daughters Olivia and Lauren, son David (who is a tax accountant at PwC), and recent first grandchild (Thomas James) – is more important to him than anything else; and one of the reasons he is retiring is to be able spend more time with them.


To conclude, I want to channel Larry Chapman, monthly weather reporter. It has been unusually fine and sunny at the Canadian Tax Foundation for the past 8 years and, although weather is changeable, thanks to Larry, the forecast for the Foundation is fine and sunny for many years to come. The personal forecast for Larry Chapman is equally favourable, since he is a man who will be successful at whatever he decides to do, although it does include ice.


Larry, I will miss you, my friend. Thank you for your support. Enjoy the next phase of your life.

Addendum

This is my 100th Arnold Report. I admit that when I started writing these blogs in 2010, I deliberately numbered them with a zero in front to implicitly suggest to readers that I intended to be writing them for several years and in the hope that they would attract sufficient readership to someday reach triple digits – and now here it is – number 100, a significant milestone.


I want to take this opportunity to thank those of you who read my reports. Without you, I’m not sure what I would have been doing for the past 5 and a half years. In particular, I want to thank Larry Chapman for giving me this dream job and only rarely stifling my rhetorical flourishes and intemperate rants – which is to say, protecting me from myself. Larry is one of only two people I know who has read every one of my reports (except this one); the other person is my longtime assistant, Carol Hargreaves, but then, that’s part of her job. I must also thank several people (you know who you are) who have read drafts for me and whose constructive criticisms have forced me to rethink and rewrite. Thank you.


There will be no zero in front of the numbers of the reports from now on, but for the time being I intend to continue churning them out.