Latest Developments in
Global Transfer Pricing
Understanding the "Nuts and Bolts" of Transfer Pricing
October 17 and 18, 2011
Optional Workshops: October 19, 2011
Kingsmill Resort · Williamsburg, VA
| Presented in partnership with: |
 | and |  |
Optional Workshop Program Agenda
Wednesday, October 19, 2011
1:00 - 4:00
Workshop Two
Tax Treaties and Their Relation to Transfer Pricing: A U.S.-Canada Perspective
Jim Wilson, Partner, National Tax Practice Group, Gowlings
- Interpretive issues involving Article IX of the Canada-U.S. Treaty
- Interaction of Article IX and XXVI of the Canada-U.S. Treaty
- Secondary adjustments
- Arbitration and the mutual agreement procedure
- Cost allocation of payroll benefits and management fees (Article IV and Article XV Issues)
- Allocation of income to a PE and notional expenses (Articles V and VII)
 Jim Wilson is a partner in Gowlings' Ottawa office, practicing in conjunction with the Firm's National Tax Practice Group. His 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'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.
| 
