Taxation

Business

CRA may apply 2025 permanent establishment OECD rules to Canada

Canadian tax lawyer and accountant David J Rotfleisch on remote work, corporate authority to bind, CRA treaty interpretation and interprovincial tax risk
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
Partner Posts

Tax season 2026: Navigating legislative changes and AI tools

Tax updates and AI tools: What practitioners need to know this tax season. Reliable and authoritative sources of tax information have never been more important
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
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
Practice

Canada's anti-deferral regime and the FAPI rules: When offshore trust structures trigger more tax

A common misconception in offshore tax planning is that tax treatment of foreign trusts is determined solely by where the trust is administered or governed
Business

Taxpayers group urges Manitoba to permanently cut gas tax as fuel prices rise

The American-Israeli assault on Iran is causing prices to surge at the pumps. Taxpayer advocacy groups are now calling for gas tax cuts to lower the impact
Practice

If a company is revived, are former directors liable for unpaid GST again?

The Maragos decision by the Tax Court of Canada reinforces the importance of limitation periods in tax law, explains Canadian tax lawyer David J Rotfleisch
Business

B.C. budget tax measures lay burden of austerity on the poorest in province

British Columbia's Finance Minister says "this is not an austerity budget." Let's look at the numbers and see for ourselves, say Marc Lee and Andrew Longhurst
Practice

Taxpayer sought judicial review of CRA's decision to refuse changing his 2004 income tax return

In Rawlings v AGC, the taxpayer successfully won the right to amend his tax return, after the Federal Court found CRA actions unfair, says David J Rotfleisch
Business

Alberta oil and gas companies lobby for tax break

Alberta is reviewing the models it uses to determine the market value of regulated properties that municipalities rely on for their own tax assessments
Practice

Accepting money from a spouse with tax problems can give you a bigger problem with the CRA

Courts will focus on economic reality, not technical form, when applying anti-avoidance provisions like section 160, explains tax lawyer David J Rotfleisch