Taxation

Thought Leaders

CRA applying GAAR for outside/inside ACB misalignment on 55(3)(a) transactions

In the final part of a three-part series, Doug S. Ewens and Kenneth Keung of Moodys Tax Law ask whether the CRA is over-reaching on the scope of the GAAR
Thought Leaders

Our response to the CRA's position on creditor-proofing reorganizations – part 2 (a case study)

A three-part series from Doug S. Ewens and Kenneth Keung of Moodys Tax Law
Practice

What can a taxpayer do if a CRA decision letter is unclear?

Canadian accountant and tax lawyer David J Rotfleisch on a recent Federal Court decision against Canada Revenue Agency
Practice

When to file (and when not to file) a service complaint against the CRA

Pierre Alary of Gowling WLG on factors that support the filing of a service complaint as part of an ongoing tax dispute
Practice

Pandora Papers: More smoke than fire? CRA VDP operations manual: Top 10 takeaways

Stevan Novoselac and John A. Sorensen of Gowling WLG on the nuances of the CRA's VDP Operations Manual
Practice

Rectification and the vanishing prospects for common sense and compassion

John Sorenson of Gowling WLG asks whether the Glenmac decision demonstrates a tax system that is just, equitable and fair
Thought Leaders

The Pandora Papers: How punishing tax cheats can serve as a deterrent

Punishing tax evasion enablers could also compel taxpayers to comply with tax laws, says Professor Tisha King, CPA, CGA
Thought Leaders

A Canadian tax lawyer's scary taxes for Halloween

From Halloween candy to the Halloween Massacre, David Rotfleisch on the tricks and treats of recent Canadian tax history
Thought Leaders

The Ancient Art Of Taxation

Vern Krishna, FCPA, FCGA on the history of taxation around the world, from ancient Mesopotamia to modern-day Canada
Practice

Analysis: Tax litigants may amend their arguments during a trial

Canadian tax lawyer and accountant David J Rotfleisch analyzes Canada v. Pomeroy Acquireco
Thought Leaders

Will the OECD eliminate corporate tax avoidance? We’ll see

Allan Lanthier analyzes the most sweeping overhaul of global tax rules in more than a century
Thought Leaders

Pandora Papers: “It’s time to pursue lawyers and accountants who enable tax evasion” – offshore tax expert Q&A

Professor Ronan Palan on the repercussions of the Pandora Papers
Practice

Canadian income tax - proposed First Home Savings Account

David J Rotfleisch on the Liberals' proposed tax favoured savings account
Profession

Sunday News Roundup 21.10.10: Pandora Papers, global tax deal, elephant tails, and more 

Wrapping up the odds and ends in this week’s Canadian accounting news
Thought Leaders

Paid millions to hide trillions: Pandora Papers expose financial crime enablers, too

Greater transparency and accountability is needed says University of Ottawa accounting professor Marc Tassé, CPA, CA
Practice

Dale et al. v the Queen – Timing on issue of shares in Section 85 rollover

Tax lawyer and accountant David J. Rotfleisch on a successful appeal of a Tax Court decision
Practice

Tax Topics We're Thinking About This Fall

MaryAnne Loney of McLennan Ross LLP on opportunities and risks in the current tax landscape
Practice

Electing out of spousal rollover on death

Toronto Tax Lawyer and Accountant David J Rotfleisch explains when, with proper estate planning, it is possible to achieve a substantially better tax outcome
Practice

When will the Tax Court of Canada resume in-person sittings?

Some notable decisions recently announced from videoconference hearings
Profession

Friday News Roundup 21.09.03: Big Four jabs, CRA secrets, minimum taxes, wealth taxes and more 

Wrapping up the odds and ends in this week’s Canadian accounting news
Practice

Tax Clearance Certificates: Canadian Tax Lawyer Guidance

Tax clearance certificates can be beneficial but may also trigger scrutiny from the Canada Revenue Agency. Canadian tax lawyer and accountant David J Rotfleisch explains
Practice

Voluntary Disclosure Applications: Canadian Tax Lawyer's Guide

Canadian tax lawyer and accountant David Rotfleisch looks at a recent Federal Court ruling on voluntary disclosure (4053893 Canada Inc.)
Business

Friday News Roundup 21.08.13: CRA errors, Xero, Freshbooks, record low insolvencies and more 

Wrapping up the odds and ends in this week’s Canadian accounting news
Practice

The general anti-avoidance rule and family surplus strips

Allan Lanthier on why the Deans Knight court decision should cause HNW individuals to pause before engaging in aggressive surplus stripping through intergenerational wealth transfers
Thought Leaders

Is the principal residence an endangered species?

The federal government is desperate for money, says Vern Krishna. Tax increases will follow a Liberal majority government