Patrick Reynaud

Specializing in tax law, Patrick dedicates his practice to litigation, dispute resolution, and audit management. He adeptly represents clients in tax disputes across various judicial levels, including trial and appellate courts, as well as in negotiations with the Canada Revenue Agency and provincial tax administrations.

His expertise spans a broad spectrum of tax-related matters, such as transfer pricing, both general and specific anti-avoidance rules, gross negligence penalties, interest relief, foreign tax credits, and issues concerning taxable employment benefits. Patrick also provides counsel on administrative and procedural aspects of tax law, access to information requests, voluntary disclosure programs, and the tax implications for charitable organizations.

A bilingual professional, Patrick is proficient in both English and French, enhancing his capability to serve a diverse client base.

Services Offered:

- Tax Controversy and Litigation

- General Tax Advisory

Highlighted Projects:

- Represented a financial institution in a Tax Court of Canada appeal challenging the application of the general anti-avoidance rule in a cross-border financing structure.

- Assisted a family estate in Tax Court of Canada proceedings to determine the fair market value of significant property.

- Advocated for an international commodities firm in a transfer pricing dispute at the Tax Court of Canada.

- Defended several holding entities in Tax Court regarding specific anti-avoidance rules and grandfathering provisions, including Federal Court actions for information access.

- Supported a pharmaceutical company in a Federal Court of Appeal motion against a Tax Court of Canada transfer pricing judgment.

Achievements:

- Recognized as an "Associate to Watch in Tax: Litigation" by Chambers Canada for 2024.

Insights and Publications:

- Authored an analysis on a Supreme Court of Canada decision regarding hedge accounting for derivative contracts.

- Examined the implications of tax avoidance penalties on eligibility for public contracts in Québec.

Professional Affiliations:

- Member of the Canadian Tax Foundation, the International Fiscal Association, and the International Law Association.

- Active volunteer with Pro Bono Ontario, offering tax advice to underrepresented clients.

Education and Credentials:

- Completed BCL/LLB with Dean's Honors at McGill University's Faculty of Law and holds a BA with Great Distinction from Concordia University.

- Furthered his education in International Relations at Université Marc Bloch, France, and completed the In-Depth Tax Course from the Chartered Professional Accountants (CPA).

Bar Membership:

- Admitted to the Québec Bar in 2012.