Jim Wilson is a partner in Gowlings’ Ottawa office, practising in conjunction with the Firm’s National Tax Practice Group. His practice focuses on helping organizations optimize 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.
Even though Jim developed an impressive specialty with tax treaties during his last 20 years with the CRA, he possesses a vast array of experience with issues such as residence and dual resident cases, permanent establishments, benefit conferrals, tower structures, e-commerce income characterization, hybrid entities, foreign entity classifications, foreign tax credit system, and Canada’s withholding tax system. From his tenure as a senior manager 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.
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