Practice

Practice

How international athletes are taxed in Canada: Toronto Maple Leafs' captain John Tavares embroiled in tax litigation with CRA

Tavares is a high-profile opportunity for the CRA to test the limits to the structuring of athlete salaries explains Canadian accountant and tax lawyer David J Rotfleisch
Practice

Case Commentary: Cassidy v Canada — using extraordinary circumstances, CRA's delays, inability to pay, or financial hardship

Why the Federal Court, in Cassidy v Canada, ruled that a CRA officer's decision was unreasonable, and the taxpayer received relief over unpaid taxes
Practice

What to do when the CRA refuses taxpayer relief

Tax accountant and lawyer David J Rotfleisch explains how a corporate director won relief from the CRA over payroll remittance in Maverick v HMK, 2023
Practice

PCAOB finds fault with half of Ernst and Young Canada audits inspected

US audit watchdog inspection report details audits with multiple deficiencies and potential non-compliance with independence rules over financial relationships
Practice

The General Anti-Avoidance Rule may be expanding: What you need to know

Aron Grusko and Nick Noonan of Fillmore Riley LLP say recent legislative changes and Supreme Court decisions reflect an increasingly expansive view of GAAR
Practice

Case Commentary: Csak v The King 2024 TCC – transfers of property while owing taxes to the CRA

David J Rotfleisch explains why the Tax Court of Canada found the Canada Revenue Agency's 1988 and 1989 reassessments statue-barred
Profession

Mystery solved: How foreign accounting firms won big in new audit client gains and losses

Among the many curiosities of the 2022 new audit client gains and losses data were the prevalence of foreign firms and the dearth of cannabis companies
Practice

Taxpayer sidesteps gross-negligence penalties and $90,000 in taxable income because tax year was statute-barred

As David J Rotfleisch explains, the decision by the Tax Court of Canada in Abbass V The King centred on a bookkeeping error by the taxpayer's accountant
Practice

Director held personally liable for unremitted and uncollected GST/HST — due diligence defence judged insufficient

Case commentary from Canadian tax accountant and lawyer David J Rotfleisch on the Tax Court of Canada decision in Hall v The King
Practice

Case Commentary: CRA violates procedural fairness for CERB/CRB claims

Canadian tax lawyer and accountant David J Rotfleisch examines the Federal Court decision in Cameron v. Canada (Attorney General) in favour of the taxpayer
Practice

Ontario Court holds that a recent former auditor cannot act as CCAA Monitor in the absence of extenuating circumstances

David Bish and Mike Noel of Torys LLP on circumstances that would cause a court to exercise its discretion to appoint a former auditor as Monitor
Practice

Made a mistake on your tax return? Here's how to change your Canadian tax return through the tax objections process

Canadian tax lawyer and accountant David J Rotfleisch explains the legal history behind the tax objections process but cautions against aggressive tax strategies
Practice

Intergenerational business transfer rules are changing in 2024

Kenneth Keung and Jason Lau of Moodys Private Client Law say tax practitioners will need to ensure they have a full understanding of new IBT rules
Practice

A new era for the Canadian GAAR

Pooja Mihailovich and Leandra Gupta of Osler, Hoskin & Harcourt LLP say the new era may compound uncertainties and add to compliance and dispute costs
Practice

Homegrown national accounting firm MNP kicks off 2024 with new Quebec acquisition

Lafond CPA merger gives MNP a foothold in the Bas-Saint-Laurent region of La Belle Province, close to the border with New Brunswick
Practice

Canadian audit watchdog CPAB bans American accounting firm BF Borgers

The Canadian Public Accountability Board closed 2023 as it had begun — with an enforcement action against an American public accounting firm
Practice

When is it worth challenging the CRA's defective Tax Court pleadings?

Tax accountant and lawyer David J Rotfleisch reconciles the Federal Court Of Appeal's decisions in the similar but different Preston and Adboss cases
Practice

A Canadian tax lawyer explains why the ATIP process is critical to preparing for tax disputes with CRA

An Access to Information or Personal Information (ATIP) request can be a double-edged sword despite its importance to resolving tax matters
Practice

Tax complexities in dealing with the death of a spouse: ODSP and child benefits

Canadian tax lawyer and accountant David J Rotfleisch looks at the concept of ghost income in a win for the taxpayer in O'Brien v. The King
Practice

Canada Revenue Agency claws back $458 million in CEWs wage subsidies from COVID-19 pandemic following audits

The CRA found cases of aggressive non-compliance among claimants using third parties for application preparation, explains Canadian tax lawyer David J Rotfleisch
Practice

Canadian taxpayers must respond to CRA about assessments, reassessments, confirmations by the deadline

In Oliveira v. The King, the Tax Court was primarily concerned with the timeliness of the application, explains Canadian tax accountant and lawyer David J Rotfleisch
Practice

Expansion of the mandatory disclosure rules in the context of ordinary commercial and routine tax planning transactions

Greg Farano of Gardiner Roberts LLP on the new MDRs, broad enough at first to apply to ordinary commercial and routine tax planning transactions
Profession

Canadian accounting firm Manning Elliott sanctioned by US audit watchdog for not disclosing CPAB censure

BC auditor was barred earlier this year by the Canadian Public Accountability Board from accepting new high- and medium-risk reporting issuer clients
Practice

Taxpayers must articulate reasons for not responding to questions in motions in Tax Court

Quigley v The King outlines the appropriate questions and responses during the discovery stage, explains tax lawyer and accountant David J Rotfleisch
Profession

Layoffs at Big Four accounting firm PwC Canada face media scrutiny over severance

Confirmation this week of layoffs at Big Four Canadian accounting firm PricewaterhouseCoopers followed PwC staff reductions in the UK and Australia