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

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