Practice

Practice

How international athletes are taxed in Canada: Toronto Maple Leafs' captain John Tavares embroiled in tax litigation with CRA

Tavares is a high-profile opportunity for the CRA to test the limits to the structuring of athlete salaries explains Canadian accountant and tax lawyer David J Rotfleisch
Practice

Case Commentary: Cassidy v Canada — using extraordinary circumstances, CRA's delays, inability to pay, or financial hardship

Why the Federal Court, in Cassidy v Canada, ruled that a CRA officer's decision was unreasonable, and the taxpayer received relief over unpaid taxes
Practice

What to do when the CRA refuses taxpayer relief

Tax accountant and lawyer David J Rotfleisch explains how a corporate director won relief from the CRA over payroll remittance in Maverick v HMK, 2023
Practice

PCAOB finds fault with half of Ernst and Young Canada audits inspected

US audit watchdog inspection report details audits with multiple deficiencies and potential non-compliance with independence rules over financial relationships
Practice

The General Anti-Avoidance Rule may be expanding: What you need to know

Aron Grusko and Nick Noonan of Fillmore Riley LLP say recent legislative changes and Supreme Court decisions reflect an increasingly expansive view of GAAR
Practice

Case Commentary: Csak v The King 2024 TCC – transfers of property while owing taxes to the CRA

David J Rotfleisch explains why the Tax Court of Canada found the Canada Revenue Agency's 1988 and 1989 reassessments statue-barred
Profession

Mystery solved: How foreign accounting firms won big in new audit client gains and losses

Among the many curiosities of the 2022 new audit client gains and losses data were the prevalence of foreign firms and the dearth of cannabis companies
Practice

Taxpayer sidesteps gross-negligence penalties and $90,000 in taxable income because tax year was statute-barred

As David J Rotfleisch explains, the decision by the Tax Court of Canada in Abbass V The King centred on a bookkeeping error by the taxpayer's accountant
Practice

Director held personally liable for unremitted and uncollected GST/HST — due diligence defence judged insufficient

Case commentary from Canadian tax accountant and lawyer David J Rotfleisch on the Tax Court of Canada decision in Hall v The King
Practice

Case Commentary: CRA violates procedural fairness for CERB/CRB claims

Canadian tax lawyer and accountant David J Rotfleisch examines the Federal Court decision in Cameron v. Canada (Attorney General) in favour of the taxpayer
Practice

Ontario Court holds that a recent former auditor cannot act as CCAA Monitor in the absence of extenuating circumstances

David Bish and Mike Noel of Torys LLP on circumstances that would cause a court to exercise its discretion to appoint a former auditor as Monitor
Practice

Made a mistake on your tax return? Here's how to change your Canadian tax return through the tax objections process

Canadian tax lawyer and accountant David J Rotfleisch explains the legal history behind the tax objections process but cautions against aggressive tax strategies