Sharon L. Gulliver

Sharon Gulliver is a senior manager of the Canadian National Tax Services group in the Ottawa office of PricewaterhouseCoopers LLP. She is also a member of PwC Global’s Tax Controversy and Dispute Resolution team. She joined the firm in September 2010.

Sharon has spent more than 35 years at the Canada Revenue Agency (CRA), including more than 22 years addressing tax avoidance and aggressive tax planning. Some highlights of her CRA career include:

• Membership in the following groups:
  • The GAAR (General anti-avoidance rule) Committee
  • The Paragraph 95(6)(b) review panel team (created in 2005 to examine referrals from the field and to approve its proposed application)
  • The Transfer pricing committee (providing input on the application of paragraph 247(2)(b))
  • The Treaty Working Group, which consists of representatives from the Legislative Policy, Ruling, Finance and Appeals, to discuss updates on treaty matters and to provide input on treaty negotiations, Organisation for Economic Co-operation and Development (OECD) initiatives, cases before the courts, international decisions, etc.
  • The Joint International Tax Shelter Information Centre Committee
• Representing the agency and/or giving presentations at various domestic and international conferences, seminars and symposiums
• Providing input for various OECD activities, including their study on tax havens, hybrids and aggressive tax planning
• Negotiating dispute resolutions with taxpayers and their representatives on tax avoidance issues: federal (domestic and international) and provincial tax avoidance cases
• Working with appeal officers and justice lawyers to discuss cases proceeding to the Court, reviewing Notices of Reply/Appeal as requested and providing input on various resolutions
• Recommending changes to the Income Tax Act