David J. Rotfleisch
Tax Law
Recent Blog Posts By David J. Rotfleisch
Equity, deadline and when CRA is at fault
A Canadian tax lawyer analysis of Dutka v. The Queen
Suing the Canada Revenue Agency for negligence
Upper level costs awarded to CRA in lengthy accounting case over SR&ED credits
The Tax Court Of Canada tests a new procedure – The Preliminary Ruling Docket
2020 initiative driven by increased objections, case backlog
1074022 B.C. Ltd. v. Li: The need for legislative reform
A misinterpretation of section 116 of the Income Tax Act in a BC real estate case
Scott v The Queen: The importance of evidence
How two brothers came under the scrutiny of the Tax Court of Canada
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