National

Practice

When fake tax losses lead to CRA gross negligence penalties: The risk of willful taxpayer blindness

The recent McCutcheon decision reinforces a fundamental principle of Canadian tax litigation, explains Canadian tax lawyer and accountant David J Rotfleisch
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
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

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
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
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
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
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
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.
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
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
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
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
Thought Leaders

Filing taxes for someone else? Here’s how to do it safely

An academic study reveals that informal tax preparers — friends and family, not professional accountants — are not using the Canada Revenue Agency’s RepID
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
Thought Leaders

Why is the CRA still targeting pandemic aid recipients?

Continued collection attempts against people who received pandemic benefits shows a punitive logic that doesn’t fit the scale of the alleged transgressions
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
Business

CEO pay at record highs as workers struggle to make ends meet: report

To reign in some of the wage disparity, a report from the Canadian Centre for Policy Alternatives offers two solutions: a millionaire tax and a wealth tax
Profession

Sunday News Roundup 26.01.18: CPA Canada membership model, fatiguing AI slop, the dealbook and more Canadian accounting news

Our weekly Canadian accounting news roundup includes the benefits of national membership, the downside of AI for accountants and businesses, and much more
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
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
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