Biography

Pierre Barsalou (a member of both the Quebec and Ontario Bars) specializes in transfer pricing and tax controversy. He has repeatedly been nominated in Best Lawyers in Canada and Lexpert in the field of corporate tax litigation, as well as a top cross-border tax litigator in Canada by Lexpert.

Pierre represents the firm’s clientele in the context of tax audits and objections as well as appeals before the Tax Court of Canada, the Federal Court and Federal Court of Appeal. He also has been active in Competent Authority proceedings, both in the context of Mutual Agreement Procedures (MAP) and Advance Pricing Arrangements (APA), and he is a frequent “upstream” advisor with respect to international tax issues.

Pierre started his career as tax counsel at the Federal Department of Justice and the Federal Department of Finance in Ottawa.

A past Governor of the Canadian Tax Foundation and a former President of the Tax Division of the Canadian Bar Association (Quebec), Pierre is also a Member of various professional associations, including the Canadian Tax Foundation (CTF), the International Fiscal Association and the Association de planification fiscale et financière (APFF).

Conferences and Publications

[Panel of Experts]
[Co-speaker], Canadian Tax Foundation, Tax and Expert Witnesses Conference, Montreal, February 20, 2019

Moderator Judge’s Panel – A discussion of topical issues in tax litigation
Canadian Tax Foundation, 67th Annual Conference, Montreal, November 2015

Income Tax – Case Update
Tax Executives Institute, 49th Tax Executives Institute Annual Canadian Tax Conference, Ottawa, May, 2015

SR&ED: An expert’s viewpoint
Scientific Research and Experimental Development Symposium, Mont Tremblant, February 23, 2015

Negotiating with tax authorities: the do’s and don’ts
Tax Executives Institute, Montreal Chapter Conference, Quebec City, February 11, 2015

Potpourri of tax administration issues (Québec): A few useful hints
Tax Executives Institute, 52nd TEI Annual Conference, February 2014

Reducing the risk of litigation: Recent Canadian and foreign judgments
Association de planification fiscale et financière (APFF), Symposium on International Tax, Hovey Manor, June 2013

Pot-Pourri on reassessments, objections and appeals
National Bank of Canada, Montreal, October 10, 2012

Tax and Ethics
Canadian Tax Foundation, Conference on Professional Ethics, Montreal, September 20, 2012

‘’Transfer pricing impact?’’
Canadian Tax Highlights, Volume 20, Number 6, June 2012

Moderator, Panel on Current Cases
Canadian Tax Foundation, 63rd Annual Conference, November 2011

Managing tax risk: 10 questions all in-house counsel should be asking and why
Canadian Corporate Counsel Association, September 30, 2011

Recent developments in transfer pricing
Canadian Tax Foundation, Technical Seminar, Montreal, June 10, 2011

Key GST-HST and QST court decisions over the years and their impact
Association de planification fiscale et financière (APFF), Indirect Tax Symposium, Montebello, May 2011

Income Tax – Beyond the GAAR: Considering judicial anti-avoidance doctrines in your transactions
Canadian Tax Foundation, 45th Annual Canadian Tax Conference, May 1-4, 2011

Managing risk in the context of tax audits
Association de planification fiscale et financière (APFF), Seminar #191, 2010

Transfer pricing audits, reassessments, and objections: how to fight back
Association de planification fiscale et financière (APFF), Annual Conference, 2009

Transfer pricing objections and appeals: Pot-pourri
Association de planification fiscale et financière (APFF), Siminar#183, 2009

Transfer pricing litigation: Practical tips (and a brief 247(2)(b) discussion)
Tax Executive Institute, Annual Conference, Ottawa, May 6, 2008

Tax decisions: Pot pourri
Tax Executive Institute, Montreal, January 15, 2008

Transfer pricing and aggressive tax planning
Canadian Tax Foundation, CRA Roundtable, Technical Seminar, June 7, 2007

Tax audits of international transactions
Association de planification fiscale et financière (APFF), Annual Conference, 2003

Tax audits, objections and appeals
Association de planification fiscale et financière (APFF), Seminar #125, 2002

Professionals and penalties, valuation and rollovers: federal and provincial similarities and differences
Association de planification fiscale et financière (APFF), Annual Conference, 2001

Doing business in North America: Update on key tax and corporate law issues
Association de planification fiscale et financière (APFF), Seminar #112, 2001

Current issues in international tax
Association de planification fiscale et financière (APFF), Seminar #98, 2000

Transfer pricing
Association de planification fiscale et financière (APFF), Seminar #98, 2000

Non-resident investment in Quebec – Tax Issues
Quebec Bar, Continuing Education
November 19, 1999

Challenging transfer pricing assessments: Objections and Appeals
International Research Institute
Annual Forum on Transfer Pricing, October 15, 1999

Selected civil law issues in a tax context
Canadian Tax Foundation, September 28, 1999

Selected Administrative Tax Issues
Association de planification fiscale et financière (APFF), Annual Conference, 1999

The do’s and don’ts when proposed adjustments are issued
Association de planification fiscale et financière (APFF), Seminar #86, 1999

Re-characterisation of commercial agreements by tax authorities: Be cautious, the sting can be painful
Quebec Bar, Conference, Quebec, June 3-5, 1999

Affiliations

Canadian Tax Foundation (CTF)
Member

Association de Planification Fiscale et Financière (APFF)
Member

International Fiscal Association (IFA)
Member