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
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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
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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
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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
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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
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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
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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
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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
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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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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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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
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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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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
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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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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
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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
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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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