Taxation

Practice
When is it worth challenging the CRA's defective Tax Court pleadings?
Tax accountant and lawyer David J Rotfleisch reconciles the Federal Court Of Appeal's decisions in the similar but different Preston and Adboss cases
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Practice
A Canadian tax lawyer explains why the ATIP process is critical to preparing for tax disputes with CRA
An Access to Information or Personal Information (ATIP) request can be a double-edged sword despite its importance to resolving tax matters
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Practice
Tax complexities in dealing with the death of a spouse: ODSP and child benefits
Canadian tax lawyer and accountant David J Rotfleisch looks at the concept of ghost income in a win for the taxpayer in O'Brien v. The King
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Thought Leaders
Australia has one of the weakest tax systems for redistribution among industrial nations – Stage 3 tax cuts will make it worse
Where does Canada rank on the global scale of income redistribution through taxation? Jim Stanford’s article on the gini coefficient provides answers
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Practice
Canadian taxpayers must respond to CRA about assessments, reassessments, confirmations by the deadline
In Oliveira v. The King, the Tax Court was primarily concerned with the timeliness of the application, explains Canadian tax accountant and lawyer David J Rotfleisch
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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
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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
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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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