Sébastien Rheault (LL.L., cum laude, Dean’s List; MBA) is a partner with Barsalou Lawson Rheault, a Top 5 Tax Law Boutique in Canada (Thompson Reuters).
He has over 20 years of experience in transfer pricing and tax controversy. He mostly represents Canadian, U.S., and European multinational corporations on audit, at the Competent Authority level in the context of Advance Pricing Arrangements (APA) and Mutual Agreement Procedures (MAP) at the Canada Revenue Agency and Revenue Quebec’s Appeals Branches, as well as before federal (Tax Court of Canada, Federal Court, Federal Court of Appeal) and provincial courts.
Sébastien also advises on various corporate tax matters including transfer pricing, tax incentives (SR&ED credits, e-business), non-resident trust rules, Canada’s income tax conventions, the General Anti-avoidance Rule (GAAR), corporate restructurings as well as mergers and acquisitions.
He recently completed his mandate as a Governor of the Canadian Tax Foundation (2015-2018). He is a board member and a past president of the Canadian Bar Association’s Tax Section (Quebec division). He presented at the Organization for Economic Co-operation and Development’s (OECD) invitation on various Base erosion profit shifting (BEPS) consultations (Work Party 6 on the transfer pricing aspects of intangible property).
Sébastien is a frequent speaker and contributor to the Canadian Tax Foundation (CTF), the Tax Executives Institute (TEI), the Association de planification fiscale et financière (APFF), the Association of Corporate Counsels (ACC), Quebec Chapter and other organizations.
He is a member of the Law Society of Ontario and the Quebec Bar.
Conferences and Publications
Transfer Pricing Conference with the Canada Revenue Agency and OECD
Canadian Tax Foundation, March 2019 (upcoming)
Transfer Pricing Panel with the Canada Revenue Agency (ITD) and OECD
APFF, Annual Tax Conference, October 2018
Transfer Pricing and BEPS under Canadian law
TEI National Conference, Ottawa, May 2017
International Tax & Transfer Pricing Panel with the Canada Revenue Agency and OECD
APFF Annual Tax Conference, October 2017
Voluntary Disclosure Programs in Canada, Quebec and U.S.
Canadian Tax Foundation, September 2017
Legal Implementation of BEPS in Canada
Canadian Tax Foundation, July 2017
Global Transfer Pricing Conference
“BEPS Driven Controversy”, Bloomberg BNA / Baker McKenzie, October 2015 (Toronto)
Transfer Pricing and International Tax Panel
APFF, Annual Tax Conferences, 2014 and 2015
Transfer Pricing and Other Current Tax Issues for Corporations (Seminar)
Association of Corporate Counsel (ACC), Montreal, March 2015
Tax Credits in the Gaming Industry
MBA Magazine – January 1, 2015
CPA Canada – Canadian Institute of Chartered Accountants
SR&ED Tax Credits Symposium, Documenting & Defending SR&ED Claims, 2015 (Toronto)
Technical Seminar on Transfer Pricing
Co-speaker with Sue Murray, Director, Competent Authority (CRA)
Canadian Tax Foundation (CTF), February 20, 2014 (Montreal) and May 28, 2014 (Ottawa)
Revenue Quebec Panel on Tax Incentives
SR&ED Tax Credits Symposium, APFF, Tremblant (2015), Esterel (2016)
Conference “Recharacterization of Transactions in Transfer Pricing Audits & Appeals”
Report of Proceedings of the Sixty-Third Tax Conference, 2011 Conference Report
Canadian Tax Foundation (CTF), 2012
LexisNexis awarded to him the mention “Distinction” according to an evaluation by his peers in tax system
Canadian Bar Association, Tax Section – Québec Division (CBA)
President, Tax Section, 2010-2012
Member and President, Tax Section , 2013-2016
Canadian Tax Foundation (CTF)
Board of Governors, 2015-2016
Association de Planification Fiscale et Financière (APFF)
Annual Conference Organizing Committee, 2015 and 2016 Annual Tax Conferences
International Fiscal Association (IFA)
MBA Association (Québec)
2000 McGill College Ave.
Canada H3A 3H3
T 514 982-3355
T 416 777-9380
F 514 982-2550