Areas of Expertise
International Tax Planning
Corporate Tax Planning
Personal Tax Planning
Sandra’s practice covers a wide range of areas, including business tax planning and dispute resolution with the CRA, with particular emphasis on reorganizations, international tax planning and financings of public corporations.
Awarded FCA, 2010
Appointed Queen’s Counsel, 2006
Called to the Alberta bar, 1990
Joined Felesky Flynn LLP, 1988
Qualified as a Chartered Accountant, 1985
Bachelor of Laws (LL.B), University of Calgary, 1989
Bachelor of Commerce (B.Comm), University of Calgary, 1982
Memberships and Associations
Member of Editorial Board for the Canadian Tax Journal
Former Member of the Executive and Council, International Fiscal Association – Canadian Branch
Past Member, Advisory Committee on Judicial Appointments for the Tax Court of Canada
Past Member, CRA Tax Professional Advisory Committee
Past Co-Chair, Joint Committee on Taxation of the Canadian Bar Association and the Canadian Institute of Chartered Accountants
Past Chair, National Tax Section of the Canadian Bar Association
Past Chair, Calgary Legal Guidance
Past Executive Committee Member, Board of Governors of the Canadian Tax Foundation
Past Director, Canadian Petroleum Tax Society
Past Chair, Taxation Specialist Section, Alberta Branch, Canadian Bar Association (Southern)
Past Director, Grace Women’s Health Council
Member, Canadian Bar Association
Member, Canadian Tax Foundation
Publications and Presentations
“OECD Report on the Transfer Pricing Aspects of Business Restructurings, OECD Forum on Tax Administration: Joint Audit Report, and CRA Review of Tax Reserve Working Papers in an International Context”, 22nd Annual Senior Tax Practitioners’ Institute, October 2010.
“Selected Recent Legislative and Administrative Developments in the Foreign Affiliate Regime”, Proceedings of the Fifty-Ninth Tax Conference, 2007 Conference Report
“Recent Transactions”, 20th Annual Senior Tax Practitioners’ Institute, October 2006
“Foreign Affiliate Amendments and Developments”, International Tax Seminar, International Fiscal Association, Canadian Branch, Toronto, May 8, 2006.
“Canada Revenue Agency Roundtable”, Report of Proceedings of the Fifty-Seventh Tax Conference, 2005 Conference Report (Toronto: Canadian Tax Foundation, 2006).
“Foreign Affiliate Amendments”, International Tax Seminar, International Fiscal Association, Canadian Branch, Toronto, May 9, 2005.
“Foreign Affiliate Amendments – February 27, 2004 Proposals”, Report of Proceedings of the Fifty-Sixth Tax Conference, 2004 Conference Report (Toronto: Canadian Tax Foundation, 2005).
“Selected Current Issues Regarding Interest Deductibility”, vol. 15 no 1 Canadian Petroleum Tax Society Journal (2002).
“Income Tax Fundamentals in a Global Economy: Old Rules and the New Reality,” Report of Proceedings of the Fifty-Third Tax Conference, 2001 Conference Report (Toronto: Canadian Tax Foundation, 2002).
“Permanent Establishment: The Canadian Perspective,” Special Seminar on Canadian Tax Treaties: Policy and Practice, 2000 IFA Conference (Toronto: International Fiscal Association, 2001), 15:1-15:35.
“The Deal: The Price Tag and Adjustment Mechanisms,” Report of Proceedings of the Fifty-Second Tax Conference, 2000 Conference Report (Toronto: Canadian Tax Foundation, 2001), 11:1-11:43.
“The Canadian Experience with VAT: The Goods and Services Tax,” American Association of Attorneys and Certified Public Accountants, July 1996. “The Foreign Affiliate Rules: The 1995 Amendments,” (1995) Vol. 43, No. 2, Canadian Tax Journal, 347-400.
“Investment in International Petroleum Opportunities: Canadian Income Tax Considerations,” Canadian Institute for Petroleum Industry Development, August 1995.
“The 1994 Amendments to the Foreign Affiliate Rules,” Report of Proceedings of the Forty-Sixth Tax Conference, 1994 Conference Report (Toronto: Canadian Tax Foundation, 1995), 26:1 – 26:48.
“Is There Substance to “Substance Over Form” in Canada?” Report of Proceedings of the Forty-Fourth Tax Conference, 1992 Conference Report (Toronto: Canadian Tax Foundation, 1993), 50:1 – 50:63. 203.