Practice
Practice
Canada's anti-deferral regime and the FAPI rules: When offshore trust structures trigger more tax
A common misconception in offshore tax planning is that tax treatment of foreign trusts is determined solely by where the trust is administered or governed
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Profession
Big Four accounting firm Deloitte Canada comes out on top in first firm-specific inspection reports from audit watchdog
KPMG Canada has highest rate of files with significant findings among Big Four firms according to reports published by Canadian Public Accountability Board
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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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Thought Leaders
Modernizing the GST/HST small-supplier threshold: A compliance fix hiding in plain sight
The issue is not whether GST/HST should exist. It’s whether the threshold governing its application still reflects sound administration in today’s economy
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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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Practice
CRA introduces software-specific controls for EFILE accounts, a safety feature, starting in 2026
Proactively reviewing EFILE accounts, certified tax software usage, and internal controls will position you far better when the new CRA rules take effect
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Practice
When judicial review (Federal Court) finds that interest imposed by CBSA must be waived
The decision in Lufthansa Technik Aktiengesellschaft offers guidance on how interest-relief applications must be evaluated under s. 3.3 of the Customs Act
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Practice
Top 5 need-to-know Canadian GST/HST cases from 2025
Simon Douville, Al-Nawaz Nanji and Randy Schwartz of McCarthy Tétrault on the top five from LBL Holdings to an AirBNB condo sale, from the FCA to Tax Court
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Practice
Case Commentary: HMK v. Quebecor Inc – Federal Court Of Appeal rejects GAAR challenge to using strategy of business losses
The FCA decision reaffirmed that tax efficiency alone does not equate to abuse under GAAR, explains Canadian tax lawyer and accountant David J Rotfleisch
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Practice
How to deduct "loss leaders," other outrageous promotional expenses on your Canadian business taxes
What Canadian tax rules apply to the deductibility of promotional expenses? Lessons from a $3.2 million giant bluefin sale and Japan's ‘Tuna King’ of sushi
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Practice
BC accounting firm Davidson & Company LLP gets clean sheet from US audit watchdog
PCAOB inspection report comes one year after censure by Canadian Public Accountability Board, based on audit inspection information from foreign regulator
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Practice
Missing a CRA notice is not an excuse: Tax Court reinforces strict deadlines to GST objections
The Tax Court of Canada’s decision in Ng v. The King used a four-step legal test for mailing, explains Canadian tax lawyer and accountant David J Rotfleisch
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Practice
Christian charities see spike in revocations for serious violations in 2025
Sometimes people think their sector is being persecuted or highlighted and that's not really the case, says CCCC spokesperson, who takes no issue with CRA
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Practice
Saskatchewan: Increases in tax credits and affordability measures
Tax credits aimed at helping with affordability are also increasing including the Low Income Tax Credit, the Disability Tax Credit and supplement and more
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Practice
Raymond Chabot Grant Thornton gets clean audit inspection sheet from US audit watchdog
A rare achievement for a Canadian accounting firm as the US Public Company Accounting Oversight Board finds no deficiencies in its inspection of two audits
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Practice
When CRA reassesses you beyond the normal period for tax shelters for charitable donations
Canadian tax lawyer and accountant David J Rotfleisch explains how a taxpayer involved in a leveraged donation scheme won in Tax Court against the CRA
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Practice
Case Study: Canada v. Hutchison Whampoa Luxembourg Holdings S.A.R.L.
The Federal Court of Appeal decision involving Husky Energy, Barbcos and Luxcos withholding tax is problematic says Lorne Saltman of Gardiner Roberts LLP
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Partner Posts
How Canadian accounting firms are governing AI to drive advisory growth
A Q&A between Andrew Kanzer of Xero and Sophie Dillon of Orbit Accountants on the adoption of AI-powered advisory services at Canadian accounting firms
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Practice
Case Commentary: Rotfleisch v. Canada – Filing an objection does not stop the alleged tax owing from accumulating interest
Canadian tax lawyer and accountant David J Rotfleisch looks at a Federal Court of Canada decision in a case going back to 2004 in which he was the applicant
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Thought Leaders
Canada needs an open finance roadmap, not just open banking
Canada has a window to learn from open banking examples around the world and design an open finance roadmap that fits its own needs says Eric Saumure, CPA
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Practice
PCAOB inspection report: Almost half of PwC Canada audits included significant deficiencies
PricewaterhouseCoopers lowered its deficiency percentage from 63 to 43 per cent, according to US audit watchdog review of seven audits conducted in 2024
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