Sammy Cheaib

Associate

Sammy Cheaib

Sammy Cheaib

Associate

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  • Québec, 2019

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.

Sammy Cheaib

Associate

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.

Mobile Content:

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. 

Mobile Content:

LKQ Corporation

Acting as Canadian counsel to LKQ Corporation in its C$2.8-billion acquisition of Uni-Select Inc.

Mobile Content:

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.

Mobile Content:

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.

Mobile Content:

Nelmar Group

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.

Mobile Content:

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.

Mobile Content:

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.

Mobile Content:

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).

Mobile Content:

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.

Mobile Content:

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.

Speaking Engagement
Mobile Content:

International Fiscal Association (U.S. and Canada Branches), YIN Webinar, “Hybridity and Hybrids: Canada's New Anti-hybrid Rules”; Webcast

Mar. 09, 2023

Bulletin
Mobile Content:

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...

Article
Mobile Content:

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).

Speaking Engagement
Mobile Content:

Association de planification fiscale et financière, 2022 Annual Conference, “Fiscalité des investissements au Canada par un non-résident”; Webinar

Oct. 06, 2022

Bulletin
Mobile Content:

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...

Bulletin
Mobile Content:

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...

Article
Mobile Content:

Novation of Debt and Payment of Accrued Interest

May 01, 2021 - Canadian Tax Focus (CTF) Vol. 11, No. 2
Download this article.

Bulletin
Mobile Content:

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...

Bulletin
Mobile Content:

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...

Bulletin
Mobile Content:

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...

Bar Admissions
Mobile Content:

Québec, 2019

Education
Mobile Content:

McGill University, BCL/LLB, 2018
McGill University, BA (Hons) (Philosophy and Psychology), 2012

Professional Affiliations
Mobile Content:

Canadian Tax Foundation
International Fiscal Association

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.

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. 

LKQ Corporation

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.

Nelmar Group

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.

Speaking Engagement

International Fiscal Association (U.S. and Canada Branches), YIN Webinar, “Hybridity and Hybrids: Canada's New Anti-hybrid Rules”; Webcast

Mar. 09, 2023

Bulletin

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...

Article

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).

Speaking Engagement

Association de planification fiscale et financière, 2022 Annual Conference, “Fiscalité des investissements au Canada par un non-résident”; Webinar

Oct. 06, 2022

Bulletin

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...

Bulletin

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...

Article

Novation of Debt and Payment of Accrued Interest

May 01, 2021 - Canadian Tax Focus (CTF) Vol. 11, No. 2
Download this article.

Bulletin

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...

Bulletin

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...

Bulletin

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...

Bar Admissions

Québec, 2019

Education

McGill University, BCL/LLB, 2018
McGill University, BA (Hons) (Philosophy and Psychology), 2012

Professional Affiliations

Canadian Tax Foundation
International Fiscal Association