Jim Wilson Partner Transfer Pricing & National Tax Group

Parle :  Anglais

Téléphone principal : +1 613-786-0196

Fax : +1 613-788-3519

Courriel : jim.wilson@gowlingwlg.com

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Bureau principal :  Ottawa

Jim Wilson

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.

  • Jim Wilson, "Managing Transfer Pricing" course, CPA Canada.
  • ​Jim Wilson and Mark Kirkey, 2018, "The Cameco Decision – What it Means for Transfer Pricing in Canada"
  • Jim Wilson and Eric Koh, September 2013, "New Limitation on Benefits Provisions in Canada's Tax Treaties – A Step Too Far?", Bloomberg BNA
  • Jim Wilson, January 2013, "Canada's New Tax Treaty with Hong Kong: 10 Key Aspects", Canadian Tax @ Gowlings newsletter, January 2013
  • Jim Wilson, Jamal Hejazi and Pierre G. Alary, May 2012, "Transfer Pricing Forum. Transfer Pricing for the International Practitioner", BNA Transfer Pricing Forum
  • Jim Wilson, Pierre G. Alary and Sandra Mah, November 2012, "Permanent Establishments – Canadian Update", BNA Transfer Pricing International Journal; Taxnet Pro
  • Jim Wilson and Pierre G. Alary, December 2012, "Canada and U.S. Announce Agreement regarding PE Attribution of Income Principles under Canada-U.S. Treaty", BNA Transfer Pricing International Journal
  • Jim Wilson, Pierre G. Alary, and Colleen McMullin, December 2012, "Three-year Statute of Limitation on Refunds of "Overpayments" for Corporations: Has CRA Opened Pandora's Box?", Practical International Tax Strategies
  • Jim Wilson and Eric Koh, December 2012, "Canada's New Tax Treaty with Hong Kong", BNA Tax Planning International Review
  • Jim Wilson, Helena Plecko and Pierre G. Alary, January 2012, "Outdated Provision of Canadian Income Tax Act Taxes Foreign Service Providers A Solution Looking for a Problem", Practical International Tax Strategies
  • Jim Wilson and Pierre G. Alary, January 2012, "Permanent Establishment Issues for Non-Resident Parent Companies with Subsidiaries in Canada", The 2012 Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada, 14th Edition, January, 2012. (Short name: 2012 Lexpert ALM 500)
  • Jim Wilson and Pierre G. Alary, December 2011, "Paragraph 212(1)(a): The Perils of an Obsolete Tax Provision", International Tax Strategies
  • Jim Wilson and Pierre G. Alary, September 2011. "CRA Provides Much Needed Guidance by Issuing PE Ruling" The International Tax Review
  • Jim Wilson, Mark Kirkey, Pierre G. Alary, Dale Hill and Jamal Hejazi, PhD, September 2011. "Transfer Pricing Forum: Dispute Resolution" BNA International Transfer Pricing Journal
  • Jim Wilson and Pierre G. Alary, June 2011. "Transfer Pricing Forum PART II: Attribution of Profits to PEs" BNA International Transfer Pricing Forum
  • Jim Wilson and Pierre G. Alary, May 2011. "Deemed Services PEs - Subcontractors vs Agents - CRA Adds Fuel to the Fire" Practical International Tax Strategies
  • Jim Wilson, May and June 2011. "Article XV(2) of the Canada -US Treaty - Problems Impacting Canadian Employees Working in the US" Practical International Tax Strategies; BNA Transfer Pricing International Journal; Lexpert.
  • Jim Wilson and Pierre G. Alary, May 2011. "TCC Rules on First Canadian Non-Discrimination Treat Case: Saipem UK Limited v. The Queen" Practical International Tax Strategies.
  • Jim Wilson, March 2011. "Current Developments Regarding Article XIII(8) of the Canada-US Treaty: From the Perspective of Dispositions of Taxable Canadian Property - Part 1" BNA Daily Tax Report.
  • Jim Wilson and Pierre G. Alary, April 2011. "Transfer Pricing Forum PART 1: Attribution of Profits to PEs", BNA International Transfer Pricing Forum.
  • Jim Wilson, Pierre G. Alary, Jamal Jejazi PhD., Dale Hill and Mark Kirkey, January 2011. "GE Capital Canada: FCA Dismisses Crown's Transfer Pricing Appeal on Guarantee Fees" Practical International Tax Strategies: BNA Transfer Pricing International Journal.

Mandats représentatifs

  • Lead advisor for a major e-commerce public company regarding a tax dispute with CRA on permanent establishment and transfer pricing issues
  • Advised on a successful judicial review application regarding a negative decision by the Canadian competent authority on a tax treaty matter
  • Lead advisor for a first of its kind advance tax ruling regarding the existence of a permanent establishment
  • Canadian representative on the editorial board for the Bloomberg BNAI Tax Treaties Analysis service

Mandats clients