TEAM

Pierre Barsalou

Pierre Barsalou

Partner

Biography

Pierre Barsalou (a member of the Quebec and Ontario Bars) specializes in transfer pricing and tax litigation. He has been cited several times in Best Lawyers in Canada and Lexpert in the area of tax litigation, and also as one of the best cross-border tax litigation lawyers in Canada by Lexpert .

Pierre represents the firm’s clients in tax audits, objections and appeals before the Tax Court of Canada, the Federal Court and the Federal Court of Appeal, as well as at the competent authority level (MAP/APA). He is also often contacted upstream regarding various international tax issues.

Pierre began his career as a tax lawyer at the Department of Justice Canada and the Department of Finance in Ottawa.

A former governor of the Canadian Tax Foundation and former president of the tax section of the Canadian Bar Association (Quebec), Pierre is also a member of several professional associations, including the Canadian Tax Foundation (CTF), the International Fiscal Association (IFA Canada) and the Association de planification fiscale et financière (APFF).

Conferences and Publications

Mandatory Disclosure Rules (including uncertain tax treatments)
Tax Executives Institute (TEI), Montreal Chapter, October 2023

Québec: What’s New and “Exciting”?
Tax Executives Institute (TEI), National Conference, May 2023

[Expert panel]
[Co-presenter] Tax and Expert Witnesses Conference
Canadian Tax Foundation (CTF), Montreal, February 20, 2019

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

Income Tax – Case Update
Tax Executives Institute (TEI), Annual Conference, Ottawa, May 4, 2015 

SR&ED Documentation: Expert’s point of view
Association de planification fiscale et financière (APFF), SR&ED Symposium, Mont Tremblant, February 23, 2015

Panel on Negotiation with Tax Authorities
Tax Executives Institute (TEI), Annual Conference, Quebec, February 11, 2015

Administrative Tax Medley (Quebec): Some useful advice
Tax Executives Institute (TEI), Annual Conference, Quebec, February 13, 2014

Litigation Prevention and Jurisprudence: Recent Canadian and foreign decisions
Association de planification fiscale et financière (APFF), Symposium on International Taxation, North Hatley, June 5-7, 2013

Potpourri Contributions, Oppositions and Appeals
National Bank of Canada, October 10, 2012

A Question of Ethics
Canadian Tax Foundation (CTF), Conference on Professional Ethics, Montreal, September 20, 2012 

”Transfer Pricing Impact of the Tim Horton OSC’s Decision”
Canadian Tax Highlights , Volume 20, No 6, June 2012

Moderator, Recent Case Law
Canadian Tax Foundation (CTF), Annual Conference, Montreal, November 27-29, 2011 

Tax Risk Management: 10 questions every legal advisor should ask and why
Association of Canadian Legal Advisors, September 30, 2011

Developments in Transfer Pricing
Canadian Tax Foundation (CTF), Technical Seminar, Montreal, June 10, 2011

List of the Most Significant Judgments in GST/HST and QST and their Impact
Association de planification fiscale et financière (APFF), Symposium on Consumption Taxes, Conference #202, 2011

Income Tax – Beyond the GAAR: Considering judicial anti-avoidance doctrines in your transactions
Tax Executives Institute (TEI), Annual Conference, Ottawa, May 1-4, 2011

Risk Management Related to Audit by Tax Authorities
Association de planification fiscale et financière (APFF), Conference #191, 2010 

Transfer Pricing – Verification, Contribution and Opposition: How to defend yourself
Association de planification fiscale et financière (APFF), Congress, 2009

Transfer Pricing Objections and Appeals: Medley
Association de planification fiscale et financière (APFF), Conference #183, 2009

Transfer Pricing Litigation: Practical tips (and a brief 247(2)(b) discussion)
Tax Executives Institute (TEI), Annual Conference, Ottawa, May 6, 2008

Tax Jurisprudence – Potpourri
Tax Executives Institute (TEI), Montreal, January 15, 2008

Transfer Pricing and Aggressive Tax Planning
Canadian Tax Foundation (CTF), Roundtable with the CRA, Tax Studies Day, June 7, 2007

Tax Audits of International Transactions
Association de planification fiscale et financière (APFF), Congress, 2003

Audits, Objections and Appeals
Association de planification fiscale et financière (APFF), Conference #125, 2002

Professional Penalties, Assessments and Rollovers: Commonalities and differences between federal and provincial
Association de planification fiscale et financière (APFF), Congress, 2001

Doing Business in America: Update on selected issues
Association de planification fiscale et financière (APFF), Conference #112, 2001

New Issues in International Taxation
Association de planification fiscale et financière (APFF), Colloquium #98, 2000

Transfer Pricing
Association de planification fiscale et financière (APFF), Colloquium #98, 2000

Investment in Quebec by a Non-Resident – Tax Aspects
Barreau du Québec, Permanent training service of the Barreau du Québec, November 19, 1999

Challenging Transfer Pricing Assessments: Objections and Appeals
International Research Institute, Annual Transfer Pricing Forum, October 15, 1999

Selected Particularities of Civil Law in a Tax Context
Canadian Tax Foundation (CTF), Montreal, September 28, 1999

Administrative Aspect
Association de planification fiscale et financière (APFF), Congress, 1999

Steps to Consider When a Contribution is Considered
Association de planification fiscale et financière (APFF), Colloquium #86, 1999

Re-Characterization of Commercial Contracts by Tax Authorities: Be careful, it can hurt
Quebec Bar, Congress, Quebec, June 3-5, 1999

Affiliations

Canadian Tax Foundation (CTF)
Member

International Fiscal Association (IFA) Canada
Member

Association de planification fiscale et financière (APFF)
Member

 

CONTACT

BARSALOU LAWSON RHEAULT LLP

2000 McGill College Avenue
Suite 1500
Montréal (Québec)
Canada H3A 3H3

T 514 982-3355
T 416 777-9380
F 514 982-2550