Overview
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 defense 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 defense work, he also oversees the groups
transfer pricing documentation and APA practice and is actively involved in
providing litigation advice to the 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, notional
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 practioner in
2008 in the Guide to the World's Leading Transfer Pricing Advisors publication.
He acquired his CPA and CFP designations in 1991 and 1995, respectively, and
completed the CICA in-depth tax course in 1999.
Practices
- Transfer Pricing
- Corporate Finance
- Audit And Assurance
- Corporate Tax
- Legal
- International Taxes
- Tax
- Business Strategy
- Tax Advisory
- Strategic Advisory
- Corporate Governance