David J. Rotfleisch
Tax Law
Recent Blog Posts By David J. Rotfleisch
Third party penalties under the Income Tax Act
Why the landmark 2015 Guindon decision by the Supreme Court of Canada matters to Canadian accountants
Director's liability and the Income Tax Act statutory limitation
Tax lawyer and accountant David Rotfleisch looks at Soulliere v The Queen
Are tax free savings account swap transactions legitimate?
In Louie v Canada, a Canada Revenue Agency cross-appeal was allowed
R. v. Scholz — A Canadian tax lawyer analysis of document forging and tax fraud
David Rotfleisch provides analysis of falsely claiming GST/HST rebates
The CRA's national policy for saying sorry to taxpayers
There are clear issues with a CRA formal apology policy, says Canadian tax lawyer and accountant David J. Rotfleisch
When does a CRA tax audit become a criminal tax investigation?
Canadian tax lawyer and accountant David J. Rotfleisch looks at the "Jarvis Standard" and the case of Softcom Solutions
Should a Canadian taxpayer seek judicial review?
The Canada Revenue Agency must provide reasons to taxpayers for their decisions, says the Federal Court of Canada
Tax fraud contrary to the Income Tax Act, the Excise Tax Act and the Criminal Code
Canadian tax lawyer and accountant David Rotfleisch looks at Regina V Reynolds
When can a Canadian taxpayer seek punitive damage from the CRA?
Tax lawyer and accountant David Rotfleisch looks at the Quebec Court of Appeal case of Ludmer c. Attorney General of Canada
The Tax Court Of Canada's new fast track settlement conference system, post the COVID-19 pandemic
Tax lawyer and accountant David Rotfleisch looks at the ramifications of trying to clear the Tax Court's backlog of cases
A Canadian tax lawyer's perspective of tax audits of COVID-19 tax fraud claims
The government will be looking out for those attempting to abuse the system, says David Rotfleisch
Duque V. The Queen: Analysis and comments on director's liability
David Rotfleisch on how the 2020 Federal Court of Appeal decision clarifies tax law for directors challenging an underlying assessment
The taxpayer's onus of proof in tax litigation: A Canadian tax lawyer's analysis
Tax lawyer and accountant David Rotfleisch looks at the case law for taxpayers challenging the Canada Revenue Agency
Tax residence of Canadian airline pilots: No simple answer
Tax Court cases illustrate subtlety of determining tax residence
Civil penalties for third-party tax advisors
Ploughman v The Queen and its implications for Canadian accountants
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
Equity, deadline and when CRA is at fault
A Canadian tax lawyer analysis of Dutka v. The Queen
Suing the Canada Revenue Agency for negligence
Upper level costs awarded to CRA in lengthy accounting case over SR&ED credits
The Tax Court Of Canada tests a new procedure – The Preliminary Ruling Docket
2020 initiative driven by increased objections, case backlog
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
Scott v The Queen: The importance of evidence
How two brothers came under the scrutiny of the Tax Court of Canada
Donor Beware: The pitfalls of participating in a donation tax shelter
The Tax Court of Canada case Abreo v. The Queen
The case of Muir v The Queen
Tax Court of Canada allows appeal over a section 160 assessment by the CRA
Hamad v. The Queen
Canadian tax lawyer and accountant David Rotfleisch on due diligence In director liability for taxes
Tax Law Analysis: Recent CRA guideline regarding cryptocurrency
Tax laywer and accountant David J. Rotfleisch on how the CRA sees cryptocurrencies