Sammy is developing a broad tax practice.
He assists clients on a range of tax matters, including tax planning and dispute resolution before the tax authorities.
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.
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.
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...