Gary Zed is a partner at Ernst & Young and is the tax market leader for Canada. He also leads the firm's tax controversy and risk management services practice. He joined Ernst& Young with more than 20 years experience in controversy management and revenue administration, and leads one of the largest controversy practices in North America.
Gary works closely with the firm's Canadian and global transfer pricing practice, as well as with international tax specialists and is responsible for handling intergovernmental relationships, issues involving double taxation, transfer pricing, and the Mutual Agreement Procedure under tax treaties. He provides strategic advice and counsel on the most complex matters and represents the firm and large multinationals before the most senior officials in the CRA. Gary manages some of the largest multinational client relationships in the world.
Gary held senior positions with both the Canada Revenue Agency (CRA) and the Department of Justice. During his tenure with the CRA, Gary was the Deputy Director General of the International Tax Directorate and also the Canadian Competent Authority responsible for tax treaty administration. He also served as the director of Transfer Pricing and Competent Authority where he had overall national responsibility for transfer pricing issues, was responsible for directing all international audit matters and directed the advance-pricing arrangement (APA) and competent authority programmes.
Before joining the international tax directorate, Gary was an experienced Justice counsel in the legal services branch of the CRA. He advised senior management and staff on a broad range of legal and policy matters affecting the revenue portfolio.
Gary has extensive knowledge of CRA operations in both headquarters and the field functions. Gary has been a frequent speaker at national and international forums and has represented the CRA in numerous international venues. He is published, has authored several articles and is frequently quoted in international journals concerning competent authority and transfer-pricing issues, and the policies and practices of the CRA. He represented Canada before the OECD, Pacific Area Tax Administrations (PATA), and the Inter-American Center of Tax Administrations (CIAT). Gary had been recognised for five consecutive years in the prestigious Legal Media Group's Guide to the World's Leading Transfer Pricing Advisers and also the Guide to the World's Leading Tax Advisers for his expertise.
LL.B., Business Law
M.B.A., Management and Marketing
Bloomberg BNA Tax Management Portfolios:
6885 T.M., Income Tax Treaties: Competent Authority Functions and Procedures of Selected Countries (A-C) (co-author)
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