David J. Rotfleisch

Tax Law

David Rotfleisch

David J. Rotfleisch, CPA, CA, JD, is the founding Canadian tax lawyer of Rotfleisch & Samulovitch, P.C., a Toronto-based boutique income tax law firm (Taxpage.com). With over 30 years of experience as both a lawyer and chartered professional accountant, he has helped start-up businesses, resident and non-resident business owners and corporations with their tax planning, with will and estate planning, voluntary disclosures and tax dispute resolution including tax litigation. Contact David at david@taxpage.com.

Recent Blog Posts By David J. Rotfleisch

Donor Beware: The pitfalls of participating in a donation tax shelter

The Tax Court of Canada case Abreo v. The Queen

The case of Muir v The Queen

Tax Court of Canada allows appeal over a section 160 assessment by the CRA

Hamad v. The Queen

Canadian tax lawyer and accountant David Rotfleisch on due diligence In director liability for taxes

Tax Law Analysis: Recent CRA guideline regarding cryptocurrency

Tax laywer and accountant David J. Rotfleisch on how the CRA sees cryptocurrencies

Bakorp Management: A milestone case for Canadian income tax law

Part I, Bakorp Management Ltd. v. Her Majesty The Queen: Choice of venue matters

Friedman: The conflict between CRA civil audits and the Canadian Charter

David Rotfleisch looks at Canada (National Revenue) v. Friedman

Canadian tax issues involving the concept of agency

Three examples as an introduction to Canadian tax issues involving agency

The tax implications of condo flipping

The primary issue for condo flippers is categorization, says David Rotfleisch

Insight: Treaties impacting on taxation

A primer from David Rotfleisch on bilateral tax agreements

Why taxpayers cannot rely on advice from the CRA

Taxpayer reassessed for acting on information given to him by the CRA

Director dodges vicarious tax liability by proving resignation

Singh v The Queen (2019 TCC 120)

Corporate amalgamation deemed an avoidance transaction

David J. Rotfleisch looks at Birchcliff Energy Ltd. v. The Queen

A caution to Canadian tax planners: Eyeball Networks Inc. v The Queen

A Butterfly reorganization might trigger derivative tax liability

A taxpayer need not answer questions during a CRA tax audit

The CRA's response to a Federal Court Of Appeal decision

Recent tightening of the Voluntary Disclosures Program

The Canada Revenue Agency's VDP and the Gauthier decision

CRA woeful disregard for taxpayer rights

Tax lawyer David Rotfleisch on latest Canada Revenue Agency communique

When can the CRA advance an alternative argument?

Subsection 152(9) of the Income Tax Act tips litigation in favour of the Crown

A taxpayer's rights to interest from the Canada Revenue Agency

A case comment on Glatt v Canada (National Revenue)

The CRA's ability to compel confidential reports

EY Canada, Atlas Tube Canada and the CRA's power to compel disclosure

Thoughts on the CRA and Canadian corporate tax gap

Are the numbers to be trusted? asks David J. Rotfleisch

Is crypto-currency trading exempt from GST/HST?

David J Rotfleisch on crypto-currency trading and the obligation to collect GST/HST

What the media missed in the Auditor General’s CRA report

Canada Revenue Agency does not accurately measure its performance

Is the CRA’s public shaming an effective deterrent of tax evasion?

The CRA is sending a clear message that tax evasion does not pay, says David J. Rotfleisch

Auditor General slams CRA for unfair treatment of taxpayers

Michael Ferguson finds the CRA unable to measure its own activities

Aitchison: A distasteful but correct Tax Court decision

The Canada Revenue Agency tried to fit a square peg into a round hole