Biography

Philippe Hamelin specializes in international and Canadian taxation and represents taxpayers before tax authorities and courts. He is currently involved, as legal counsel, in major files regarding transfer pricing, SR&ED tax credits, payroll tax, the taxation of insurance contracts as well as residency and permanent establishment issues. Philippe also handles various cases involving international and tax treaty issues.

As a skilled negotiator, he has resolved favorably, without the necessity of litigation, the majority of the cases he worked on. In addition to being recognized for his abilities (e.g., he is cited by Best Lawyers®), Philippe is appreciated for his pragmatic approach focused on clients’ needs.

Philippe completed his law degree (LL.B.) at the University of Montreal (cum laude; Dean’s Honour List) where he won the Barreau de Montréal prize for excellence in civil law (1st of his class). A member of the Quebec Bar since 2014, he is on the Honour Roll of the Quebec Bar school having placed second at the Quebec Bar exam.

Panel on recent caselaw (SR&ED), with the participation of the Tax Court of Canada
Co-speaker, Association de planification fiscale et financière (APFF), SR&ED symposium, April 2023

Panel with the OECD and CRA: Update on the Two-Pillar Solution (OECD) and update on Business Audits (CRA)
Co-speaker, Association de planification fiscale et financière (APFF), Annual Conference, Montreal, October 2022

“Pillar II: A Canadian Case Study”, in 2022 Transfer Pricing Conference (Toronto: Canadian Tax Foundation, 2022) 4: 1-42
Ana Mata Zapico, Philippe G. Penelle, Philippe Hamelin and Julien Tremblay-Gravel

Pillar II: A Canadian Case Study
Co-speaker, Canadian Tax Foundation (CTF), May 2022

Employee Mobility: Taxation related to teleworking as well as physical return to the office (if applicable), legal aspect
Co-speaker, Association de planification fiscale et financière (APFF), Annual Conference, Montreal, October 2021

Roundtable on SR&ED with the Canada Revenue Agency
Co-panelist with CRA, Association de planification fiscale et financière (APFF), SR&ED Symposium, April 2021

Teleworking tax issues in the Covid-19 era
Co-speaker, Canadian Tax Foundation (CTF), January 2021

Employers and Employees: Tax treatment of expenditures incurred to facilitate or allow teleworking
Co-speaker, The Canadian Bar Association (Quebec Division), November 13, 2020

Panel with CRA: Request and exchange of information
Co-speaker, Association de planification fiscale et financière (APFF), Annual Conference, Montreal, October 2019

Panel with CRA: Audit and how to mitigate risks (international taxation)
Co-speaker, Association de planification fiscale et financière (APFF), Annual Conference, Montreal, October 2019

SR&ED litigation: From objection to Tax Court
Co-panelist with CRA and Justice, Association de planification fiscale et financière (APFF), SR&ED Symposium, April 2019

Recent provincial caselaw
Co-speaker, Tax Executives Institute (TEI), Montreal Chapter, 57th Annual Conference, February 2019

Tax aspects of intellectual property
Co-speaker, Canadian Tax Foundation (CTF), May 2018

Roundtable with Revenue Quebec: Optimization and interaction of tax incentives
Co-speaker, Association de planification fiscale et financière (APFF), SR&ED Symposium, March 2018

Tax administration component of the SR&DE program
Co-speaker, Association de planification fiscale et financière (APFF), SR&ED Symposium, March 2018

Roundtable with Revenue Quebec: Optimization and interaction of tax incentives
Co-speaker, Association de planification fiscale et financière (APFF), Annual Conference, Quebec, October 2017

Fairmont Hotels Inc. and Jean Coutu Group (PJC) Inc. Supreme Court decisions on rectification
Co-speaker, Canadian Tax Foundation (CTF), Conference / Webcast, Montreal, January 2017

Deduction for Innovative Manufacturing Corporations
Association de planification fiscale et financière (APFF), Annual Conference, Montreal, October 2016

Tsunami in SR&ED: Important recent jurisprudence
Association de planification fiscale et financière (APFF), Annual Conference, Quebec, October 2015

Roundtable with Revenue Quebec – Quebec SR&ED Symposium: Clarifications and Positions Taken by Revenue Québec
Co-author, Stratège Magazine, June 2015

Abeilles Service de Conditionnement Inc. v. The Queen: Support for Taxpayers Claiming SR&ED Tax Credits
Stratège Magazine, March 2015

Tax Credits in the Gaming Industry
Co-author, Magazine MBA, January 2015

Roundtable on International Taxation
Co-speaker, Association de planification fiscale et financière (APFF), Annual Conference, Montreal, October 2014

Affiliations

Canadian Tax Foundation (CTF)
Member

Association de planification fiscale et financière (APFF)
Member