National

Practice

A guide to the Canadian tax treatment of domestic, foreign retirement compensation arrangements for high-income earners

Canadian tax lawyer and accountant David J Rotfleisch deconstructs lessons from the recent Tax Court Martin v The King decision involving the CRA and RCAs
Practice

Landmark Canadian tax law decision that limits CRA's authority under section 231.2 of Income Tax Act

Canadian tax lawyer and accountant David J Rotfleisch examines the decision in Canada (National Revenue) v Shopify Inc., against the Canada Revenue Agency
Practice

The Date Debate: A new battleground in assessment appeals

An Ontario Assessment Review Board decision is sparking debate about how many valuation dates there are in the provincial property tax assessment system
Practice

Case Commentary: Osman v The King – GST/HST new housing rebate claim denied due to lack of intention to occupy property first

Canadian tax lawyer and accountant David J Rotfleisch explains the clear and settled intention to occupy property as a primary place of residence concept
Practice

Losses, expenses arising from transactions that are not 'sufficiently commercial' may be ineligible to reduce your income tax

Canadian tax lawyer and accountant David J Rotfleisch explains why the Tax Court dismissed the FX trade case of a successful businessman in Chad v The King
Practice

How the CRA uses 'nudge letters' with online sellers to increase uptake of Canada's VDP

Canada Revenue Agency uses nudge letters to prompt taxpayers to review their tax affairs, ensure compliance, and access the Voluntary Disclosures Program
Practice

Case Analysis: Why a business must demonstrate actual business activities before applying for business tax deductions

David J Rotfleisch examines the case of a chartered professional accountant who claimed business expenses for a company he cofounded in Prince Edward Island
Practice

Tax Court Of Canada is not ‘slap-dash,' nor tolerates sloppy examination for discovery

David J Rotfleisch explains why the Tax Court of Canada, in Whistler Blackcomb Holdings Inc. v The King, 2025, dismissed the CRA's motion for a new nominee
Practice

Loss-trading transactions to avoid paying tax disallowed by Tax Court Of Canada (GAAR rule)

In Total Energy Services v. HMK, the FCA upheld a Tax Court ruling that complex transactions satisfied three conditions of the general anti-avoidance rule
Profession

Sunday News Roundup 25.05.04: Federal election disappoints accountants and more Canadian accounting news

Our weekly Canadian accounting news roundup includes election disappointment among conservative accountants, the PCAOB fighting to survive, and more.
Practice

Case Commentary: Ayre v the King – Convoluted charitable gifts made through questionable financing transactions

Canadian tax lawyer and accountant David J Rotfleisch examines donative intent under Section 118.1 of the Income Tax Act in a pharmaceutical donation case
Business

Brampton: The Carbon Tax Gamble – The ‘cost of climate inaction’ will be bigger than short-term relief at the pump

A feature report from Brampton, Ontario on the history of carbon pricing in Canada and how the consumer carbon tax was sacrificed in a political chess game