Sammy provides innovative and practical solutions to clients’ complex tax matters.
He acts for clients on the tax aspects of public and private mergers and acquisitions, investments, reorganizations and financings.
Sammy also acts for individuals, family offices and private companies on personal estate and tax planning matters.
Interactive Validated Solutions 88 Inc.
Acted for the shareholders, including Desjardins Capital, Anges Québec capital and a large group of angel investors, of Interactive Validated Solutions 88 Inc., a company specializing in SaaS quality, compliance and traceability solutions, in its sale to TradeBeyond, a Hong Kong based leading supply chain platform.
HID Global Corporation
Acted for HID Global, a subsidiary of Swedish conglomerate Assa Abloy, in its acquisition of Vancouver-based Guard RFID Solutions, a manufacturer of real-time location systems used in healthcare environments.
Ember Infrastructure Management, LP
Acting for funds managed by Ember Infrastructure Management, LP, a New York-based private equity firm, in its $395-million acquisition of H2O Innovation Inc., a TSX-listed company, by way of statutory plan of arrangement under the Canada Business Corporations Act, and the associated rollover of shares by Investissement Québec, Caisse de dépôt et placement du Québec and management.
Acting as Canadian counsel to LKQ Corporation in its C$2.8-billion acquisition of Uni-Select Inc.
Sprott Resource Lending Corp.
Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the financing (of up to US$25 million) of Elemental Royalties' acquisition of a portfolio of precious metal royalties from a wholly owned subsidiary of South32 Limited.
Sprott Resource Lending Corp.
Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the financing (of up to US$105 million) of Ascot Resources Ltd.'s Premier Gold Project in northern British Columbia. The terms of the financing included a senior credit facility, a convertible credit facility and a production payment agreement.
Acted for the shareholders of Nelmar Security Packing Systems Inc., Plastixx Extrusion Technologies Inc. and Plastixx FFS Technologies Inc. in the sale of their 100% interest to Balcan Plastics Ltd., a subsidiary of BDT Capital Partners.
Hypertec Infrastructures Inc.
Acted as lead tax counsel for Hypertec Infrastructures Inc. in the sale of its data center and colocation services business to Vantage Data Centers, one of the world's leading hyperscale data center providers.
Boutique Linus Inc.
Acted for Boutique Linus Inc. which operates Fortnine.ca, a leading Canadian online retailer and distributor in the powersports industry, in a sale of an interest to Novacap.
NDT Global Corporate
Acted as Canadian tax counsel to Ireland-headquartered NDT Global, a leading supplier of ultrasonic pipeline inspection and data analysis, on its sale to Caisse de dépôt et placement du Québec/Novacap-backed Eddyfi Technologies, a Québec-based innovative private test & measurement technology group focused on non-destructive testing (NDT).
Hillcore Financial Corporation
Acting for Hillcore Financial Corporation and related entities (the Taxpayers) in their dispute before the Tax Court of Canada with respect to trading in foreign exchange derivative contracts and other related disputes.
Private Equity Firm
Representing a private equity group before the Tax Court of Canada in connection with a dispute involving foreign exchange forward contracts in what is commonly referred to as "straddle" trading undertaken by a substantial number of taxpayers.
Acted for 12625164 Canada Inc., an affiliate of Thread Collective Inc. in connection with a transaction whereby Thread Collective Inc. transferred to 12625164 Canada Inc. all of its assets relating to its Psycho Bunny business and the subsequent investment by The BB Family International Trust in 12625164 Canada Inc.
Tax Executives Institute, « Mise à jour sur les pouvoirs de vérification de l’ARC », Montréal, QC
May 31, 2023
International Fiscal Association (U.S. and Canada Branches), YIN Webinar, “Hybridity and Hybrids: Canada's New Anti-hybrid Rules”; Webcast
Mar. 09, 2023
The CRA’s New Power to Compel Oral Interviews
Jan. 17, 2023 - The Canada Revenue Agency (CRA) can now require taxpayers or any other person to answer “all proper questions” and provide all reasonable assistance for any purpose relating to the administration or enforcement of the Income Tax Act (ITA), including by submitting to oral questioning at a...
FISCALITÉ INTERNATIONALE – Survol général des nouvelles règles d’asymétrie hybride, co-author
Oct. 19, 2022 - Stratège, Vol. 27, No. 3 (APFF)
Download this article (in French).
Association de planification fiscale et financière, 2022 Annual Conference, “Fiscalité des investissements au Canada par un non-résident”; Webinar
Oct. 06, 2022
Top Court Blesses Treaty-Shopping Arrangement: The Alta Energy Decision
Dec. 14, 2021 - The Supreme Court of Canada (SCC) recently rendered its eagerly awaited decision in Canada v Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 (Alta Energy). Six of the nine justices held that the Canadian statutory general anti-avoidance rule (GAAR) did not apply to deny treaty...
Parliament Votes to Facilitate Intergenerational Business Transfers
July 23, 2021 - Bill C-208, An Act to amend the Income Tax Act (transfer of small business or family farm or fishing corporation), which aims to amend section 84.1 of the Income Tax Act (Act) received royal assent on June 29, 2021. A majority of the House of Commons had voted in May on...
Novation of Debt and Payment of Accrued Interest
May 01, 2021 - Canadian Tax Focus (CTF) Vol. 11, No. 2
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CRA Turns Its Focus to Cryptocurrency Transactions
Apr. 13, 2021 - The Federal Court (FC) recently authorized the Canada Revenue Agency (CRA) to issue an “unnamed persons requirement” (UPR) to Coinsquare Ltd. for information and documentation relating to users of Coinsquare, a cryptocurrency exchange operating in Canada. This UPR is part of an on-going CRA...
Disclosure Rules for Nominee Contracts Come into Force in Québec
Oct. 02, 2020 - Bill 42, An Act to give effect to fiscal measures announced in the Budget Speech delivered on 21 March 2019 and to various other measures was assented to on September 24, 2020, bringing into force the new rules respecting the disclosure of nominee contracts to Revenu Québec (RQ ). The...
Canada Enacts the OECD-Sponsored Multilateral Instrument
June 26, 2019 - Canada has enacted into law the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The enactment of June 21, 2019 represents the penultimate step in the domestic ratification of the MLI in Canada, which will...
CRA’s Audit Powers Have Limits: Challenging Excessive Requests for Information
June 25, 2019 - In three recent decisions, the courts have curtailed the Canada Revenue Agency’s (CRA’s) broad interpretation of its audit powers and, in so doing, have armed taxpayers with the legal means to push back against excessive or unreasonable requests for information (RFIs) by the CRA. First, in...
The CRA Cannot Compel Oral Interviews During an Audit
Apr. 10, 2019 - In Minister of National Revenue v Cameco Corporation, the Federal Court of Appeal (FCA) dismissed the Minister of National Revenue’s appeal and held that the Canada Revenue Agency’s (CRA’s) audit powers under the Income Tax Act (ITA) do not extend to compelling taxpayers to be...