Taxation

Practice

The meaning of HST 'included in' the purchase price for real property (after the CRA has assessed the HST)

Greg Farano of Gardiner Roberts LLP on a court case involving an HST registrant who self-assessed HST on the value of commercial portion of a sold property
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
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
Business

Alberta farmers lukewarm about federal gas tax suspension

Suspension of the federal fuel excise tax by the now majority government of Mark Carney will pressure on the UCP Smith government in Alberta to follow suit.
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
Practice

A taxing situation: Can Canadian tech contractors working for U.S. or overseas companies incorporate?

Aron Grusko and Nick Noonan of Fillmore Riley LLP explore the tax and legal considerations of incorporation for professionals in Canada working remotely
Business

Ontario: Province announces lower business tax

The provincial government is proposing to cut Ontario’s small business corporate income tax rate from 3.2 per cent to 2.2 per cent as of July 1 this year
Business

CRA may apply 2025 permanent establishment OECD rules to Canada

Canadian tax lawyer and accountant David J Rotfleisch on remote work, corporate authority to bind, CRA treaty interpretation and interprovincial tax risk
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
Partner Posts

Tax season 2026: Navigating legislative changes and AI tools

Tax updates and AI tools: What practitioners need to know this tax season. Reliable and authoritative sources of tax information have never been more important
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
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