Jim Wilson

Canada
International Tax

Jim Wilson is a partner in the Taxand Canada office Gowlings', in Ottawa, practising in conjunction with the Firm's National Tax Practice Group. His practice focuses on helping organisations optimise their global tax position and reduce exposure to unfavourable audit assessments through proper tax planning and implementation strategies.

Jim’s tax experience involves the administration of domestic corporate and international tax with the Canada Revenue Agency (CRA) for 32 years. Jim held various positions with CRA's Income Tax Rulings Directorate ("Rulings"), the Canadian Competent Authority Division ("Competent Authority"), the Training and Learning Directorate and the Legislative Policy Division. During Jim's tenure as both a senior officer and a senior manager of the International Section in Rulings, he participated in hundreds of Advanced Income Tax Rulings and Technical Interpretations on a wide range of international technical issues. As a senior manager with Competent Authority for six years, Jim has been successful in resolving a number of controversial international double tax cases through successful negotiations with tax authorities in a number of countries around the world. From his tenure with Competent Authority Services, Jim's experience expanded to a multitude of technical and policy issues pertaining to the CRA's MAP and APA programs. This would include expertise on ACAPs, interest relief, secondary adjustments, notional expenses, imputed interest, Article XIII(8) agreements, and S-Corp agreements.

Jim possesses a vast array of experience with issues such as residence and dual resident cases, permanent establishments, benefit conferrals, tower structures, e-commerce income characterisation, hybrid entities, foreign entity classifications, foreign tax credit system, and Canada's withholding tax system.

Jim acquired his CGA designation in 1987. For a period of approximately 10 years he was also the CGA Ontario instructor, in the Ottawa Region, for its Advanced Tax Program.

Areas of Expertise

• International Tax
• Tax Treaties

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