David J. Rotfleisch
Tax Law
Recent Blog Posts By David J. Rotfleisch
Director dodges vicarious tax liability by proving resignation
Singh v The Queen (2019 TCC 120)
Corporate amalgamation deemed an avoidance transaction
David J. Rotfleisch looks at Birchcliff Energy Ltd. v. The Queen
A caution to Canadian tax planners: Eyeball Networks Inc. v The Queen
A Butterfly reorganization might trigger derivative tax liability
A taxpayer need not answer questions during a CRA tax audit
The CRA's response to a Federal Court Of Appeal decision
Recent tightening of the Voluntary Disclosures Program
The Canada Revenue Agency's VDP and the Gauthier decision
CRA woeful disregard for taxpayer rights
Tax lawyer David Rotfleisch on latest Canada Revenue Agency communique
When can the CRA advance an alternative argument?
Subsection 152(9) of the Income Tax Act tips litigation in favour of the Crown
A taxpayer's rights to interest from the Canada Revenue Agency
A case comment on Glatt v Canada (National Revenue)
The CRA's ability to compel confidential reports
EY Canada, Atlas Tube Canada and the CRA's power to compel disclosure
Thoughts on the CRA and Canadian corporate tax gap
Are the numbers to be trusted? asks David J. Rotfleisch
Is crypto-currency trading exempt from GST/HST?
David J Rotfleisch on crypto-currency trading and the obligation to collect GST/HST
What the media missed in the Auditor General’s CRA report
Canada Revenue Agency does not accurately measure its performance
Is the CRA’s public shaming an effective deterrent of tax evasion?
The CRA is sending a clear message that tax evasion does not pay, says David J. Rotfleisch
Auditor General slams CRA for unfair treatment of taxpayers
Michael Ferguson finds the CRA unable to measure its own activities
Aitchison: A distasteful but correct Tax Court decision
The Canada Revenue Agency tried to fit a square peg into a round hole
Federal Court upholds CRA audit powers
Charter Challenge: Campbell v Attorney General of Canada, 2018 FC 683
Fighting the Canada Revenue Agency no longer like fighting city hall
The Ludmer decision represents a judicial thawing of CRA liability
U.S. tax ruling means winter is coming for online retailers
Tax rulings are catching up with the Amazons of retail
Multiple taxpayers successfully sue the Canada Revenue Agency
Damages in negligence: Ludmer et al c. Attorney General Of Canada
Voluntary Disclosures Program under continued attack from Canada Revenue Agency
VDP changes are headed to the courts, predicts tax lawyer David J. Rotfleisch
The reasonable minimum standard when challenging CRA tax audits
A look at the leading case and subsequent case law
CRA discipline statistics shockingly low for number of service complaints
Tax lawyer David Rotfleisch says taxpayer abuse should be disciplined as well
A world of difference between CRA civil and criminal tax audits
The Income Tax Act is clear on Canada Revenue Agency civil and criminal audits. But what happens when the goal of a CRA civil audit is to lay criminal charges?
Canada Revenue Agency: solicitor-client privilege for commonly interested parties
Solicitor-Client privilege bars the CRA from compelling legal-advice documents when a taxpayer discloses to a party with a common interest, says tax lawyer David J. Rotfleisch
Canada Revenue Agency farcical in treatment of taxpayers
David Rotfleisch on CRA behaviour, from malicious prosecution to the dead parrot voluntary disclosures program