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.
Sébastien and other members of the firm participate and contribute to the ‘Defi 808 Bonneville’, a cycling event organized to raise funds and support high-level athletes through college and university studies, as well as their respective sports, while promoting role models for aspiring young athletes in the Province.
Conferences and Publications
TEI – Los Angeles, Morgan Lewis Tax Controversy Seminar, February 2020
Exchange of Information: Issues, Use and Collaboration, 2019
Life Sciences Law in Canada, 2nd Edition (Chapter on tax aspects including transfer pricing and tax incentives), 2019
Introduction to International Tax in Canada, 6th edition, Thomson Reuters (co-author/collaboration – Cash Pooling Arrangements), 2019
Transfer Pricing: Review of Canadian caselaw and pending cases, 2019
IFA – National Tax Conference
Co-panelist with CRA on International Exchanges of Information, Montreal, May 2019
International Fiscal Association
TEI – Annual National Tax Conference
Co-panelist on CRA access to tax provisions and related matters
Tax Executives Institute, Ottawa, May 2019
CTF – Transfer Pricing Conference with the Canada Revenue Agency and OECD
Canadian Tax Foundation, March 2019
APFF – Transfer Pricing Panel with the Canada Revenue Agency (ITD) and OECD
Annual Tax Conference, October 2018
TEI – Transfer Pricing and BEPS under Canadian law,
Tax Executives Institute, National Conference, Ottawa, May 2018
APFF – International Tax & Transfer Pricing Panel with the Canada Revenue Agency and OECD
Annual Tax Conference, October 2017
CTF – Voluntary Disclosure Programs in Canada, Quebec and U.S.
Canadian Tax Foundation, September 2017
CTF – Legal Implementation of BEPS in Canada
Canadian Tax Foundation, July 2017
APFF- Quebec Revenue Congress on Fiscal Advantages
Symposium Crédits fiscaux en SR&ED, Tremblant, 2015 and Esterel, 2016
Global Transfer Pricing Conference
“BEPS Driven Controversy”, Bloomberg BNA / Baker McKenzie, Toronto, October 2015
APFF – Transfer Pricing and International Tax Panel
Annual Tax Conferences, 2014 and 2015
ACC – Transfer Pricing and Other Current Tax Issues for Corporations (Seminar)
Association of Corporate Counsels, 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, Toronto, 2015
CTF – Technical Seminar on Transfer Pricing
Co-speaker with Sue Murray, Director, Competent Authority (CRA)
Canadian Tax Foundation, Montreal, February 20, 2014 and Ottawa, May 28, 2014
CTF – LexisNexis lui a attribué la mention “Distinction” selon une évaluation par ses pairs en fiscalité
Canadian Tax Foundation, 2012
CTF – Recharacterization of Transactions in Transfer Pricing Audits & Appeals
Canadian Tax Foundation, Annual Conference – Report of Proceedings of the 63rd Tax Conference, 2011
Canadian Bar Association, Tax Section – Québec Division (CBA)
President, Tax Section, 2010-2012
Member and President, Tax Section , 2013-2019
Canadian Tax Foundation (CTF)
Board of Governors, 2015-2019
Association de Planification Fiscale et Financière (APFF) (Quebec Tax Association)
Annual Conference Organizing Committee, 2015 and 2016 Annual Tax Conferences
International Fiscal Association (IFA)
MBA Association (Québec)
Association of Corporate Counsel (ACC)
Bloomberg BNA / Baker McKenzie Transfer Pricing Conference
Canadian Institute of Chartered Accountants (CPA Canada)
International Fiscal Association (IFA)
Tax Executive Institute (TEI)
2000 McGill College Ave.
Canada H3A 3H3
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T 416 777-9380
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