Jim Wilson

About Jim Wilson

Jim Wilson helps organizations manage their worldwide tax position and keep the risk of an unfavourable audit low, with planning that's built to be carried out properly. As a partner in Gowling WLG's Ottawa office, Wilson sits in the Transfer Pricing & National Tax Group, with a listed focus on transfer pricing competent authority matters.

That focus grew out of 32 years at the Canada Revenue Agency, where Wilson administered domestic corporate and international tax. Over that time the roles ranged across the Income Tax Rulings Directorate, the Canadian Competent Authority Division, the Training and Learning Directorate and the Legislative Policy Division. In the International Section of Rulings, serving as both a senior officer and a senior manager, Wilson worked on hundreds of advance rulings and technical interpretations covering international tax questions. Six years as a senior manager in Competent Authority meant negotiating with tax authorities abroad, and Wilson resolved a number of contested double tax cases that way.

Tax treaties became a real specialty during the CRA years. Still, the experience reaches well past treaties into inbound and outbound Canadian tax questions such as permanent establishments, foreign affiliates, FAPI and withholding tax, along with technical and policy issues under the CRA's MAP and APA programs.

Wilson earned the CGA designation in 1987 and spent roughly a decade teaching CGA Ontario's Advanced Tax Program in the Ottawa region. Articles on transfer pricing, permanent establishments and Canada's treaties have run in BNA journals, The International Tax Review and elsewhere.