Dale C. Hill Partner Tax Services, National Leader - Transfer Pricing & Competent Authority Group

Parle :  Anglais

Téléphone principal : +1 613-786-0102

Fax : +1 613-788-3473

Courriel : dale.hill@gowlingwlg.com

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Bureau principal :  Ottawa

Dale C. Hill

Dale Hill is a partner in Gowling WLG's Ottawa office and is the national leader of the Gowling WLG 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. Dale's specialty is audit defence and dispute resolution, where he has been instrumental in preventing various tax authorities in North America, Europe and Asia, from raising costly transfer pricing adjustments and penalties on some of the world's largest multinational companies.

In addition to Dale's audit defence work, he also oversees the groups transfer pricing documentation and APA practice and is actively involved in providing litigation advice to firm clients from a tax perspective. With significant experience dealing with Asian governments and businesses alike, he assists the firm's largest Asian clients in optimizing their global operations from a transfer pricing perspective. Dale has worked in a variety of industries including, but not limited to, pharmaceuticals, auto, construction, consumer durables and computer software industries.

Dale's ability to solve contentious issues draws from his experience vast experience working at the Canada Revenue Agency (CRA) at a senior level. Prior to joining Gowling WLG in 2005, Dale was involved in international transfer pricing and tax avoidance with the 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, national expenses, penalties and appeals. Dale has been successful in resolving a number of controversial audit issues through successful 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.

Dale's expertise has been recognized many times by various institutions. His group was awarded with Canada Transfer Pricing Firm of the Year Award by International Tax Review for the years 2011, 2013, and 2015. His group won the Finance Monthly Transfer Pricing Firm of the Year in 2012. Dale was also named pre-eminent practitioner in 2008 in the Guide to the World's Leading Transfer Pricing Advisors. He acquired his CPA and CFP designations in 1991 and 1995, respectively, and completed the CICA in-depth tax course in 1999.

Recognized as a pre-eminent transfer pricing practitioner through his work at both the CRA and at Gowling WLG, Dale is routinely asked to give seminars on transfer pricing and related tax matters to both government bodies (India and Singapore) and industry groups alike, both domestically and internationally.

Dale has presented at numerous conferences in Asia, Europe and North America. He has given presentations through a number of outlets including, but not limited to, Canadian Tax Foundation, Infonex, Importer Exporter, CPA Society and Tax Executive institute. Dale is routinely asked to provide expert commentary on various tax issues. These outlets include, but is not limited to, the Globe and Mail and Business Without Borders.

Dale has published widely in leading tax journals including Tax Notes International, Practical International Strategies, North American Free Trade and Investment Report, as well as Lawyers Weekly. Dale's group has completed two books and is close to completing a third book on transfer pricing.

In May 2022, Dale weighed in with CBC regarding accusations that the Canadian Revenue Agency violated its own policy and exposed its reputation to damage when it granted a secretive tax deal to a major corporation.

In June 2022, alongside partners Pierre Alary and André Bergeron, Dale was an instructor for the GTA Accountants & GTA Finance Network course "Update - What's Up at CRA and The Fundamentals and Key Issues Relating to Transfer Pricing."

Dale is an instructor for CPA Canada's "Managing Transfer Pricing" course.