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Sameer Nurmohamed
Sameer Nurmohamed (he, him, his) Partner | Toronto

About Sameer

Sameer specializes in tax controversy and litigation. He has represented financial institutions, mutual funds, and international and domestic businesses from a broad array of industries, including telecommunications, real estate, finance, utilities, and entertainment/media.

Sameer has extensive experience dealing with transfer pricing, Canada's general anti-avoidance rule (GAAR), interest and guarantee fee deductibility, tax treaties, tax avoidance rules, goods and services tax/harmonized sales tax, derivatives, rectifications, voluntary disclosures, valuations, and capital/income characterization.

Sameer is skilled at dealing with the Canada Revenue Agency and provincial tax authorities to resolve disputes and navigate audits. He has also appeared before the Tax Court of Canada, the Ontario Superior Court of Justice, and the Ontario Court of Justice.

Before joining Blakes, he practised tax litigation at another national law firm and, prior to that, was a clerk for the Tax Court of Canada.

Select Experience
  • A telecommunications corporation in the settlement of a tax dispute regarding the deduction of guarantee and other fees

  • Real estate development corporations in a successful motion hearing resolving several related transitional land credit tax disputes

  • A U.S. entertainment corporation in the settlement of a Part XIII withholding tax dispute involving an exemption under the Canada-U.S. tax treaty

  • Utilities and real estate corporations in several settlements of tax disputes regarding the characterizations of repair and maintenance expenses as income or capital

  • A telecommunications corporation in the settlement of a tax dispute regarding the valuation of cross-border intellectual property

  • A multinational corporation in the settlement of a tax dispute regarding GAAR

  • Several corporations in successfully eliminating Ontario Ministry of Finance tax assessments

  • A Canadian entity in the settlement of regulatory proceedings

  • A multinational conglomerate in obtaining a rectification order

Awards & Recognition

Sameer is a recipient of the "Best Newsletter Article by a Young Practitioner Award" by the Canadian Tax Foundation for his article "Tax Benefit" for GAAR: The Defences, Canadian Tax Focus, Vol. 11, No. 1, 2021.

He is also recognized as a leading tax lawyer in Best Lawyers: Ones to Watch in Canada 2023.

Professional Activities

In addition to speaking frequently at events in the industry, Sameer serves as the vice-chair of the Ontario Bar Association's Tax Executive and as the chair of the Canadian Tax Foundation's Young Practitioners Group. He also acts as a mentor with the Federation of Asian-Canadian Lawyers and several universities.

Sameer volunteers extensively with not-for-profits, including as a former board member of Basic Income Canada Network and an advisor with UBI Works.

He has completed the Canadian Bar Association's program on tax law for lawyers and CPA Canada's three-year in-depth tax course.

  • Co-author : Allowing Appeals on Procedural Grounds without regard to the Substantive Correctness of the Tax Assessment
    Tax Litigation, Volume XXVI, No. 2, Federated Press, 2023.
Professional Appearances
  • Author : Case Law Update
    Toronto Young Practitioners Group Meeting, Canadian Tax Foundation, Toronto, Ontario, December 12, 2023.
  • Moderator : What it Means to Be a Tax Lawyer
    University of Toronto Tax Law Society, Toronto, Ontario, November 1, 2023.
  • Moderator : Diversity of Jurisdiction Over Tax Disputes
    Celebrating the Tax Court of Canada, Canadian Tax Foundation, October 6, 2023.
  • Moderator : The Ins and Outs of CRA Tax Audits: Process and Resolution
    Ontario Bar Association, Toronto, Ontario, April 6, 2023.
  • Moderator : Bad Facts Make Bad Law? A Review of Deans Knight and a Young Practitioners Mixer
    Canadian Tax Foundation, December 14, 2022.
  • Presenter : Trends in CRA Requests for Information and Documents
    74th Annual Tax Conference, Canadian Tax Foundation, November 27, 2022.
  • Speaker : A Practical GAAR Update
    Young Practitioners Focus Conference, Canadian Tax Foundation, September 7, 2022.
  • Speaker : Case Law Update
    Young Practitioner Webinar Series, Canadian Tax Foundation, Toronto, Ontario, March 31, 2022.
  • Panellist : Tax Law Panel
    Osgoode Hall Tax Law Association, Toronto, Ontario, November 8, 2021.

LLM, University of Ottawa – 2015
Admitted to the Ontario Bar – 2014
MA (Economics), University of Toronto – 2013
JD, University of Toronto – 2013
BA (Dean's List), Cornell University – 2010

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