David J. Rotfleisch
Tax Law

David J. Rotfleisch, CPA, CA, JD, is the founding Canadian tax lawyer of Rotfleisch & Samulovitch, P.C., a Toronto-based boutique income tax law firm (Taxpage.com). With over 30 years of experience as both a lawyer and chartered professional accountant, he has helped start-up businesses, resident and non-resident business owners and corporations with their tax planning, with will and estate planning, voluntary disclosures and tax dispute resolution including tax litigation. Contact David at david@taxpage.com.
Recent Blog Posts By David J. Rotfleisch

CEWS forms for COVID-19 relief will lead to tax fraud, fuel cash economy
Those who don’t remember tax history are doomed to repeat it, says David Rotfleisch
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Equity, deadline and when CRA is at fault
A Canadian tax lawyer analysis of Dutka v. The Queen
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Suing the Canada Revenue Agency for negligence
Upper level costs awarded to CRA in lengthy accounting case over SR&ED credits
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The Tax Court Of Canada tests a new procedure – The Preliminary Ruling Docket
2020 initiative driven by increased objections, case backlog
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1074022 B.C. Ltd. v. Li: The need for legislative reform
A misinterpretation of section 116 of the Income Tax Act in a BC real estate case
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Scott v The Queen: The importance of evidence
How two brothers came under the scrutiny of the Tax Court of Canada
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Donor Beware: The pitfalls of participating in a donation tax shelter
The Tax Court of Canada case Abreo v. The Queen
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The case of Muir v The Queen
Tax Court of Canada allows appeal over a section 160 assessment by the CRA
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Hamad v. The Queen
Canadian tax lawyer and accountant David Rotfleisch on due diligence In director liability for taxes
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Tax Law Analysis: Recent CRA guideline regarding cryptocurrency
Tax laywer and accountant David J. Rotfleisch on how the CRA sees cryptocurrencies
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Bakorp Management: A milestone case for Canadian income tax law
Part I, Bakorp Management Ltd. v. Her Majesty The Queen: Choice of venue matters
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Friedman: The conflict between CRA civil audits and the Canadian Charter
David Rotfleisch looks at Canada (National Revenue) v. Friedman
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Canadian tax issues involving the concept of agency
Three examples as an introduction to Canadian tax issues involving agency
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The tax implications of condo flipping
The primary issue for condo flippers is categorization, says David Rotfleisch
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Insight: Treaties impacting on taxation
A primer from David Rotfleisch on bilateral tax agreements
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Why taxpayers cannot rely on advice from the CRA
Taxpayer reassessed for acting on information given to him by the CRA
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Director dodges vicarious tax liability by proving resignation
Singh v The Queen (2019 TCC 120)
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Corporate amalgamation deemed an avoidance transaction
David J. Rotfleisch looks at Birchcliff Energy Ltd. v. The Queen
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A caution to Canadian tax planners: Eyeball Networks Inc. v The Queen
A Butterfly reorganization might trigger derivative tax liability
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A taxpayer need not answer questions during a CRA tax audit
The CRA's response to a Federal Court Of Appeal decision
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Recent tightening of the Voluntary Disclosures Program
The Canada Revenue Agency's VDP and the Gauthier decision
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CRA woeful disregard for taxpayer rights
Tax lawyer David Rotfleisch on latest Canada Revenue Agency communique
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When can the CRA advance an alternative argument?
Subsection 152(9) of the Income Tax Act tips litigation in favour of the Crown
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A taxpayer's rights to interest from the Canada Revenue Agency
A case comment on Glatt v Canada (National Revenue)
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The CRA's ability to compel confidential reports
EY Canada, Atlas Tube Canada and the CRA's power to compel disclosure
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