David J. Rotfleisch
Tax Law
Recent Blog Posts By David J. Rotfleisch
SR&ED: The CRA cannot use its civil tax audit power to gather information for a criminal investigation
David J Rotfleisch explains why the Federal Court of Appeal ruled in favour of the CRA in a Scientific Research and Experimental Development tax credits case
Sweet v Canada: Federal Court Of Canada certified privacy breach class action against CRA
Canadian accountant and tax lawyer David J Rotfleisch on the latest privacy class action lawsuit to be certified by the Federal Court of Canada
The reasonability requirement for administrative suspension of EFILE rights
Canadian tax lawyer and accountant David J Rotfleisch on Virgen v Canada (Attorney General), a Federal Court decision in favour of an Ontario tax preparer
Rectification saves taxpayers from adverse tax consequences arising from drafting error
A KPMG tax planning document saved Sleep Country from the consequences of a numerical error, explains Canadian accountant and tax lawyer David J Rotfleisch
Another historical development in claiming negligence against the CRA
Canadian accountant and tax lawyer David J Rotfleisch on the Myers ruling
Singh v. Canada: A Canadian tax lawyer's observations on TFSA penalties
As taxpayers, we are ultimately responsible for meeting our obligations under tax law, as explained by Canadian accountant and tax lawyer David J Rotfleisch
Tax Court orders CRA to release GAAR committee reports about similarly situated taxpayers
Canadian accountant and tax lawyer David J Rotfleisch explains why the Committee's legal analysis fell within within the scope of discovery
The Ontario Ministry Of Finance's Voluntary Disclosures Program – A Canadian tax lawyer's summary
David J. Rotfleisch explores the differences between the federal and Ontario VDPs
Preston Family Trust II v The Queen: Assumptions of facts in replies to a notice of appeal
Just the facts, ma'am: David J. Rotfleisch explains why the Tax Court of Canada would strike out the CRA's legal assumptions in a notice of appeal
New proposed mandatory tax planning reporting obligations under the Canadian Income Tax Act
Amendments to the new rules were made in August 2022 and are likely to become law says Canadian accountant and tax lawyer David J Rotfleisch
Barrs v The Queen: Taxpayer relief under S.220(3.1)
Canadian accountant and tax lawyer David J Rotfleisch on a Federal Court of Appeal case involving a CRA's review officer's failure to engage with a request for equitable treatment
MNR v Zhao: CRA collection action when there are reasonable grounds for delay
Canadian accountant and tax lawyer David J Rotfleisch on the Canada Revenue Agency’s successful jeopardy order in a high-profile BC real estate case
Tax pipeline planning: A Canadian tax lawyer's guide and case study
A pipeline plan is a tool used to avoid paying tax on dividends to pay tax on capital gains explains David J Rotfleisch
FCA overturns Tax Court's decision because the CRA's evidence was about the taxpayer’s spouse
Canadian accountant and tax lawyer David J. Rotfleisch on the Khanna v The Queen decision by the Federal Court of Appeal, which overturned a Tax Court ruling
The Queen v Paletta – The legal test for business income
Tax lawyer and accountant David J. Rotfleisch on the CRA's successful appeal of a Tax Court of Canada ruling regarding foreign currency trading
Zvilna v. The Queen: Director's liability for unpaid taxes, a note of caution to directors
Tax lawyer and accountant David J. Rotfleisch on the successful appeal of a director’s liability assessment before the Tax Court of Canada
Transferring cryptocurrency to a bare trustee or holding cryptocurrency as a bare trustee
Tax lawyer and accountant David Rotfleisch on Canadian cryptocurrency tax planning through the use of bare trusts
A Canadian tax lawyer's guide on net worth assessments – Halls v The Queen, 2022 TCC 14
Canadian accountant and tax lawyer David Rotfleisch on a net worth assessment win for the CRA involving a taxpayer's record keeping
How to use BVI or other offshore non-CCPCs to save tax on investment income
Canadian tax lawyer and accountant David Rotfleisch the risks (and rewards) of the British Virgin Islands tax avoidance strategy
A Canadian tax lawyer's perspective on income tax statute-barred periods
David J Rotfleisch on the timing legalities of reassessments
A Canadian tax lawyer's perspective on Tax Court of Canada minutes of settlement vs. consent to judgment
David J Rotfleisch on settling a dispute prior to a hearing in Tax Court
RRSP double taxation from overcontribution
Tax lawyer and accountant David J Rotfleisch on double taxation and relief
Reeves v the Queen & applicability of the GST/HST new housing rebate
Tax lawyer and accountant David J Rotfleisch on why a homebuyer was denied the new housing rebate by the Tax Court of Canada
Tax Court rules that gift of shares of a private corporation to a foundation was ineligible for a charitable tax credit
Tax lawyer and accountant David J Rotfleisch on gifting non-qualifying securities such as a promissory note to a registered charity
What can a taxpayer do if a CRA decision letter is unclear?
Canadian accountant and tax lawyer David J Rotfleisch on a recent Federal Court decision against Canada Revenue Agency
