Dorothy O'Shea.

• Position: Sharing best tax practices - Interview

"When I graduated from university with a bachelor of commerce degree with a major in accounting, I would never have imagined that my career path would have led me to spending the majority of my career in tax," Dorothy O'Shea says.

But O'Shea, currently head of tax for General Mills Canada, has indeed immersed herself in tax--big time. She started in accounting but quickly moved into industry in an internal audit role. "It was from there that I embarked upon my career in tax with an insurance company, and only then did I realize I enjoyed the field of taxation," O'Shea says.

O'Shea's experience in the insurance, entertainment, and consumer products industries proved invaluable. "I had the good fortune to have been given the opportunity to work for a few different companies in very different businesses and to work for both U.S. and Canadian multinationals," she explains. Through these experiences, she learned that some companies have very complex business models, others have complex organizational structures, and some have both. "Some industries are subject to different sections of the Tax Act. No matter what industry, the different tax issues can be very challenging. The most interesting for me has been working on international transactions within complex organizational structures. I have also learned that the common thread throughout every type of industry is transfer pricing," O'Shea notes.

Transfer Pricing: Center Stage

Indeed, for O'Shea, transfer pricing is the most interesting part of corporate tax. For example, she points out, "The OECD's BEPS initiatives are likely to have the most significant impact on the taxation of businesses internationally in nearly three decades. The focus on transparency and the onerous reporting requirements will certainly increase the compliance burden for our profession. In Canada, we have already seen a shift in the way the Canada Revenue Agency performs their audits."

The most problematic tax law problem O'Shea has encountered in her distinguished career involved the challenge to a third-party valuation by government authorities for a cross-border transaction. "Valuations are complex and often challenged because of the underlying assumptions built into the valuation models," she explains. "Although we were successful in having the issue we faced vacated upon appeal, the process was a costly and time-consuming burden for the taxpayer."

The TEI Connection

O'Shea values her TEI membership. The networking...