David J. Rotfleisch
Tax Law
Recent Blog Posts By David J. Rotfleisch
Federal Court upholds CRA audit powers
Charter Challenge: Campbell v Attorney General of Canada, 2018 FC 683
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.
Death Knell: The Canada Revenue Agency Voluntary Disclosures Program
Tax Lawyer David Rotfleisch says that, contrary to popular opinion, the CRA's changes to the VDP will affect the poor and middle class more than the rich
What are the ethical obligations of a tax professional?
Tax Lawyer David J. Rotfleisch on the ethical obligations of accountants and lawyers in practice
CRA goes fishing for PayPal users on hook for taxes
The Canada Revenue Agency is looking to catch PayPal-registered businesses not declaring income or tax
Trouble in Paradise: The end of tax haven secrecy
Cyberattacks on tax haven law firms means client records are no longer confidential
Bill Morneau’s backpedalling recalls past tax debacles
Tax lawyer David J. Rotfleisch says the tax reversal would have likely occurred in a U.S. scenario as well
Morneau tax amendments an assault on entrepreneurs
Canadian Accountant columnist David J. Rotfleisch says Bill Morneau's tax proposals hurts small business owners
Feeling Lucky? CRA tax evasion convictions on downward trend
The Canada Revenue Agency has released its latest audit statistics. Tax lawyer David J. Rotfleisch says they won’t encourage voluntary disclosure
VDP Changes: The Law of Unforseen Consequences
A closer look at the Canada Revenue Agency’s proposed changes to the Voluntary Disclosures Program and their ramifications
Breaking the VDP when it doesn’t need fixing
Tax lawyer David Rotfleisch says proposed changes by the Canada Revenue Agency to the Voluntary Disclosures Program are bad ones
Black Money or 'Why I can’t find workers to build my cottage'
Welcome to the black money, underground economy of the construction sector. My cottage can wait for an honest worker
The CRA & KPMG: Far from a sweetheart deal
The deal offered to KPMG's clients is the deal I would have expected, says David Rotfleisch