Taxation

Practice

Expansion of the mandatory disclosure rules in the context of ordinary commercial and routine tax planning transactions

Greg Farano of Gardiner Roberts LLP on the new MDRs, broad enough at first to apply to ordinary commercial and routine tax planning transactions
Practice

Taxpayers must articulate reasons for not responding to questions in motions in Tax Court

Quigley v The King outlines the appropriate questions and responses during the discovery stage, explains tax lawyer and accountant David J Rotfleisch
Practice

Tax obligations for foreign home buyers In Canada: Bakhtiari v British Columbia

Can a refugee avoid paying the foreign buyer’s tax on human rights grounds under the Canadian Constitution? David J Rotfleisch comments on the Bakhtiari case
Profession

Sunday News Roundup 23.11.12: Quebec transfer pricing, CRA interest and more Canadian accounting news

Wrapping up the odds and ends from the past week in Canadian accounting news
Practice

Canadian taxpayers, beware: The CRA gets away with defective pleadings during tax litigation

In Canada v. Preston, the Federal Court of Appeal sided with the Canada Revenue Agency and overturned the Tax Court's decision, over the issue of assumptions
Practice

Are hybrid sales of private businesses still a viable tax planning tool for business owners?

David J Rotfleisch explores whether the Foix decision by the FCA radically undermines the tax benefits of a hybrid sale when selling a private business
Practice

The GAAR reinforcements — What even is economic substance?

With the economic substance wording in the general anti-avoidance rule, Finance Canada has given a present to the tax judiciary, says Raymond G. Adlington
Practice

Tax planning is changing in 2024

MaryAnne Loney of McLennan Ross LLP looks at three areas of tax planning related to private corporations that will change in 2024
Practice

A Canadian tax lawyer's guide to the In-Trust-For (ITF) Account

Canadian tax accountant and lawyer David J. Rotfleisch discusses ITFs, including tax implications, issues and alternatives to these unregistered investment accounts
Practice

Canadian taxpayer involved in a bad will investment scheme granted additional relief on accrued interest

Relief requests beyond the statute of limitation may still be available, depending on the circumstances, explains tax accountant and lawyer David J Rotfleisch
Practice

Court orders delivery of tax planning memo prepared by accountants to CRA

Laurie Goldbach and Steve Suarez of BLG on disclosure of tax planning documents and the Tax Court's treatment of accountant-client privilege
Practice

Tax fraud and tax evasion in the same case: Analysis of Regina v Reynolds

A case before the BC Supreme Court included violations of the Income Tax Act and Excise Tax Act explains Canadian accountant and lawyer David J Rotfleisch