National
Practice
How to beat CRA alternative tax assessments: Insights from a Canadian tax lawyer
Canadian tax lawyer and accountant David J Rotfleisch presents four strategies based on recent judicial decisions to undermine these CRA tax assessments
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
Aggressive tax planning schemes, specially those designed by third parties, will annoy CRA – Canada v. Microbjo Properties Inc.
The Federal Court of Appeal in this case made it clear that true arm’s length dealings require independent interests, real negotiation, and genuine risk
- COMMENTS 13
- LIKES 149
- VIEWS 160
Thought Leaders
Meet a millionaire who wants Canada to tax the rich
Tech entrepreneur Avi Bryant is a member of the Patriotic Millionaires, a group of wealthy Canadians advocating for changes to the country's taxation system
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
How disobeying a Federal Court order under the Income Tax Act will result in ‘contempt of court’ charge plus fines & penalties
As David J Rotfleisch explains, the courts make a clear distinction between the inability to comply and a lack of effort, when it comes to contempt of court
- COMMENTS 13
- LIKES 149
- VIEWS 160
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
- COMMENTS 13
- LIKES 149
- VIEWS 160
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
- COMMENTS 13
- LIKES 149
- VIEWS 160
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
- COMMENTS 13
- LIKES 149
- VIEWS 160
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
- COMMENTS 13
- LIKES 149
- VIEWS 160
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
- COMMENTS 13
- LIKES 149
- VIEWS 160
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
- COMMENTS 13
- LIKES 149
- VIEWS 160
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
- COMMENTS 13
- LIKES 149
- VIEWS 160
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
- COMMENTS 13
- LIKES 149
- VIEWS 160
