National

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