Practice

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.
Thought Leaders

Modernizing the GST/HST small-supplier threshold: A compliance fix hiding in plain sight

The issue is not whether GST/HST should exist. It’s whether the threshold governing its application still reflects sound administration in today’s economy
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
Practice

Top 5 need-to-know Canadian GST/HST cases from 2025

Simon Douville, Al-Nawaz Nanji and Randy Schwartz of McCarthy Tétrault on the top five from LBL Holdings to an AirBNB condo sale, from the FCA to Tax Court
Practice

Case Commentary: HMK v. Quebecor Inc – Federal Court Of Appeal rejects GAAR challenge to using strategy of business losses

The FCA decision reaffirmed that tax efficiency alone does not equate to abuse under GAAR, explains Canadian tax lawyer and accountant David J Rotfleisch
Practice

How to deduct "loss leaders," other outrageous promotional expenses on your Canadian business taxes

What Canadian tax rules apply to the deductibility of promotional expenses? Lessons from a $3.2 million giant bluefin sale and Japan's ‘Tuna King’ of sushi
Practice

BC accounting firm Davidson & Company LLP gets clean sheet from US audit watchdog

PCAOB inspection report comes one year after censure by Canadian Public Accountability Board, based on audit inspection information from foreign regulator
Practice

Missing a CRA notice is not an excuse: Tax Court reinforces strict deadlines to GST objections

The Tax Court of Canada’s decision in Ng v. The King used a four-step legal test for mailing, explains Canadian tax lawyer and accountant David J Rotfleisch
Practice

Christian charities see spike in revocations for serious violations in 2025

Sometimes people think their sector is being persecuted or highlighted and that's not really the case, says CCCC spokesperson, who takes no issue with CRA