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Dale Hill is a partner in Gowlings' Ottawa office and is the national leader of the Gowlings 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.
Prior to joining Gowlings in 2005, Dale was involved in international transfer pricing with the Canada Revenue Agency ("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, tax avoidance, ACAP, 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.
He acquired his CMA and CFP designations in 1991 and 1995, respectively, and completed the CICA in-depth tax course in 1999.
Dale has published widely in leading tax journals including Tax Notes International, North American Free Trade and Investment Report, as well as Lawyers Weekly.
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