David J. Rotfleisch
Tax Law
Recent Blog Posts By David J. Rotfleisch
Fighting the Canada Revenue Agency no longer like fighting city hall
The Ludmer decision represents a judicial thawing of CRA liability
U.S. tax ruling means winter is coming for online retailers
Tax rulings are catching up with the Amazons of retail
Multiple taxpayers successfully sue the Canada Revenue Agency
Damages in negligence: Ludmer et al c. Attorney General Of Canada
Voluntary Disclosures Program Under Continued Attack from Canada Revenue Agency
VDP changes are headed to the courts, predicts tax lawyer David J. Rotfleisch
The reasonable minimum standard when challenging CRA tax audits
A look at the leading case and subsequent case law
CRA discipline statistics shockingly low for number of service complaints
Tax lawyer David Rotfleisch says taxpayer abuse should be disciplined as well
A world of difference between CRA civil and criminal tax audits
The Income Tax Act is clear on Canada Revenue Agency civil and criminal audits. But what happens when the goal of a CRA civil audit is to lay criminal charges?
Canada Revenue Agency: Solicitor-Client Privilege For Commonly Interested Parties
Solicitor-Client privilege bars the CRA from compelling legal-advice documents when a taxpayer discloses to a party with a common interest, says tax lawyer David J. Rotfleisch
Canada Revenue Agency farcical in treatment of taxpayers
David Rotfleisch on CRA behaviour, from malicious prosecution to the dead parrot voluntary disclosures program
How effective is the CRA at closing Canada’s tax gap?
How good is the Canada Revenue Agency at closing the tax gap? We’ll find out this year from the Parliamentary Budget Office if the CRA has indulged in PR spin.
