Taxation
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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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Practice
Deans Knight will have a serious impact on tax planning & tax disputes
The courts will increasingly gravitate toward the minority approach in the Deans Knight decision, assert the tax lawyers of Counter Tax Litigators
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Thought Leaders
Wealthy but worried: why the UK’s top 10% are turning their backs on the rest of society
A thought leadership article on high income earners in the UK may hold some insights into Canadian attitudes towards inequality and taxation among the wealthy
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