Jim Wilson is a partner in Gowling WLG's Ottawa office, practising in conjunction with the firm's Tax 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 was 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.
Although Jim developed an impressive specialty with tax treaties during his time with CRA, he possesses a vast array of experience with all inbound and outbound Canadian tax issues, including residence, permanent establishments, foreign affiliates, FAPI and Canada's withholding tax regimes. 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 includes 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 for its Advanced Tax Program in the Ottawa region.