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.
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 be...
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...