National
Practice
CRA real estate tax audits using MLS data: Builder risk, GST/HST exposure & audit defence strategies In Canada
In one year alone, more than 2,200 GST/HST tax audits specifically targeting housing transactions resulted in approximately $231 million in tax assessments
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Practice
10 Canadian tax facts you ought to know
With the recent release of Canadian Tax Facts 2026 from David J Rotfleisch, now is the time to test your knowledge and assumptions about Canadian taxation
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Practice
How to avoid the 'tax trap' on timing of flow-through for dividend income and timing of receipts for trusts
Canadian tax lawyer and accountant David J Rotfleisch examines the FCA decision in Vefghi Holding Corp. v. Canada, currently under leave to appeal at the SCC
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Practice
Contempt of court in Canadian tax litigation is a high bar in Canada
The MNR v Carflex decision illustrates the high evidentiary threshold that must be satisfied before a taxpayer or corporate officer can be found in contempt
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Practice
Unpaid payroll deductions: Federal Court Of Appeal affirms bona fide purchaser defence for unsecured creditors
Toronto-Dominion Bank v. Canada confirms that innocent unsecured creditors are not automatically liable to repay unremitted payroll deductions to the Crown
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Practice
When a donation is not really a gift: The court's rejects on tax-driven charity arrangements, gifts must be genuine
The Federal Court of Appeal decision in Walby v Canada reinforces an important principle in Canadian tax law, says tax lawyer and accountant David J Rotfleisch
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Practice
If a company is revived, are former directors liable for unpaid GST again?
The Maragos decision by the Tax Court of Canada reinforces the importance of limitation periods in tax law, explains Canadian tax lawyer David J Rotfleisch
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Practice
Taxpayer sought judicial review of CRA's decision to refuse changing his 2004 income tax return
In Rawlings v AGC, the taxpayer successfully won the right to amend his tax return, after the Federal Court found CRA actions unfair, says David J Rotfleisch
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Practice
Accepting money from a spouse with tax problems can give you a bigger problem with the CRA
Courts will focus on economic reality, not technical form, when applying anti-avoidance provisions like section 160, explains tax lawyer David J Rotfleisch
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Practice
When taxpayer relief, CPP limitation periods, and procedural finality abandon fairness without a remedy
Tolley v The King is a reminder that developments after tax reassessments, no matter how convincing, cannot alter relief from reassessments retroactively.
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Practice
Superstars, Steroids and Succession
Enhancing a succession plan using Succession Enhancers is like hitting a grand slam without any controversy involved, says Matthew Getzler of Torkin Manes LLP
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Practice
When CRA employees misbehave and make mistakes against Canadian taxpayers
The Canada Revenue Agency distinguishes clearly between employee misconduct and wrongdoing, applying different legal and administrative frameworks to each
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