Biography

Sébastien Rheault (LL.L., cum laude, Dean’s List; MBA) is a partner with Barsalou Lawson Rheault LLP, a Top 5 Tax Law Boutique in Canada (Thomson Reuters).  He is a Member of the Law Society of Ontario and the Quebec Bar.

With over 20 years of experience in transfer pricing, litigation and tax controversy (Highly Regarded ranked in Euromoney and International Tax Review), Sébastien primarily represents multinational corporations on audit, at the Competent Authority level (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 served as a Governor of the Canadian Tax Foundation (2015-2018) and as president of the Canadian Bar Association’s Tax Section (Quebec division). He was a member of the CPA-ABC Joint Committee on Taxation and 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).

Sebastien is a frequent speaker and contributor to the Canadian Tax Foundation (including as a member of the organizing committee for Transfer Pricing Conferences), the Tax Executives Institute (TEI), the Association de planification fiscale et financière (APFF) and the Association of Corporate Counsels (ACC).

Along with other members of the firm, he participates and contribute annually to the ‘’Defi 808 Bonneville’’, an endurance cycling event that raises funds allowing to accompany high-level student-athletes in Canada through college and university studies, to support them financially in their pursuit of academic and sports excellence, and to contribute to the promotion of models in Quebec society at the Fondation de l’athlète d’excellence du Québec (FAEQ).

Conferences and Publications

NABE – Annual Transfer Pricing Symposium
July 2023

APFF – Annual Congress
Association de planification fiscale et financière, Annual Tax Conference, October 2022

Cambridge – International Forum on Transfer Pricing Law
Annual Tax Conference, England, October 2022

NABE – Annual Transfer Pricing Symposium (TPS)
July 2022

CTF – Transfer Pricing Conference
Canadian Tax Foundation, May 2022

TP MINDS – Transfer Pricing Professionals In The Americas
February 2022

Cambridge – International Forum on Transfer Pricing Law
Annual Tax Conference, January 2022

CTF – Annual Tax Conference
Canadian Tax Foundation, November 2021

APFF – Annual Congress
Association de planification fiscale et financière, Annual Tax Conference, September 2021

IFA – International Tax Conference
International Fiscal Association, May 2021

CTF – Transfer Pricing Conference with the CRA and OECD
Canadian Tax Foundation, February 2021

APFF – Annual Congress
Association de planification fiscale et financière, Annual Tax Conference, October 2020

IFA – International Conference
International Fiscal Association, May 2020

TEI – Tax Controversy Seminar, Morgan Lewis
Tax Executives Institute, Los Angeles, 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”, 6^th 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 Canada Revenue Agency on International Exchanges of Information
International Fiscal Association, Montreal, May 2019

TEI – Annual National Tax Conference
Co-panelist on Canada Revenue Agency 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
Association de planification fiscale et financière, 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
Association de planification fiscale et financière, 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
Association de planification fiscale et financière, 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

AMBAQ – “Tax Credits in the Gaming Industry”
MBA Magazine – MBA Association of Quebec, January 1^st, 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 at 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 on Report of Proceedings of the 63^rd Tax Conference, 2011

Affiliations

Canadian Bar Association, Tax Section – Québec Division (CBA)
President, Tax Section, 2010-2012
Member and President, Tax Section, 2013-2019

Canadian Tax Foundation (CTF)
Member, Board of Governors, 2015-2019

Association de Planification Fiscale et Financière (APFF) (Quebec Tax Association)
Member of the Organizing Committee of the Annual Tax Conferences, 2015 and 2019

International Fiscal Association (IFA)
Member

MBA Association of Quebec (AMBAQ)
Member

Association of Corporate Counsel (ACC)
Member

Bloomberg BNA / Baker McKenzie Transfer Pricing Conference
Member

Canadian Institute of Chartered Accountants (CPA Canada)
Member

INFONEX
Member

Tax Executive Institute (TEI)
Member