Gowling Lafleur Henderson LLP
Date: Friday, October 18, 2013
Time: 12:30pm - 2:00pm
Venue: The Canadian Chamber of Commerce in Hong Kong
Suite 1301 Kinwick Centre, 32 Hollywood Road, ,,,,,,,, Central, Hong Kong
Price: Free of charge, registration required.
About the Event:
The presentation will be given by Jim Wilson and Dale Hill, who will provide an overview of transfer pricing in Canada and will also highlight important aspects of the Canadian tax system. The main focal point will be on issues that multinational corporations face when doing business in Canada. Part of the presentation will focus on the issue of double taxation and the specific dispute resolution mechanisms Hong Kong multinational companies, upon ratification of the Canada-Hong Kong Tax Treaty, will be able to pursue when attempting to relieve double taxation in Canada. Dispute mechanisms discussed will include competent authority and the appeals process. They will also examine tax planning strategies including the Advanced Pricing Agreement and how such strategies can be used to gain tax certainty for multinational corporations operating in Canada.
With Jim’s tax experience involving the administration of domestic corporate and international tax with the Canada Revenue Agency (CRA) for 32 years, he will also discuss Canadian permanent establishment issues and current CRA policies and audit activity. The presentation will also cover cross-border employee issues, and employer withholding obligations.
About the Speakers:
Jim Wilson's practice focuses on helping organizations optimize their global tax position and reduce exposure to unfavorable audit assessments through proper tax planning and implementation strategies. 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. 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 10 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. 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.
Dale is the national leader of the Gowlings Transfer Pricing and Competent Authority team. Dale works in conjunction with the Firm's National Tax Practice Group to help organizations optimize their global tax position and reduce exposure to unfavourable audit assessments through proper tax planning and implementation strategies.
Prior to joining Gowlings in 2005, Dale was involved in
international transfer pricing with the Canada Revenue Agency
("CRA") for 16 years. During his tenure as a senior manager with
the CRA's International Tax Directorate, he participated in more than 40 Advanced
Pricing Agreements ("APAs") with numerous countries, as well
as hundreds of Competent Authority requests relating to international
transfer pricing adjustments involving a vast array of issues. He is also
experienced in a number of other international tax areas, including
interest deductibility, guarantee fees, imputed interest, notional
expenses, tax avoidance, ACAP, penalties and appeals. Dale has been
successful in resolving a number of controversial audit issues
through negotiations with various tax authorities in a number of countries
around the world.
In 2004, Dale led the development of a national field
strategy that defined the working relationship between the CRA's Competent
Authority, tax services offices, appeals and head office, with respect to
audit adjustments to Canadian taxpayers and audit adjustments initiated by
foreign countries. He acquired his CMA and CFP designations in 1991 and
1995, respectively, and completed the CICA in-depth tax course in
1999. Dale's expertise was recognized in 2011 when Gowlings was recognized
by the International Tax Review as Canada’s Transfer Pricing Firm of the