Taxation

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
Thought Leaders

‘We got lazy and complacent’: Swedish pensioners explain how abolishing the wealth tax changed their country

For much of the 20th century, Sweden enjoyed a justifiable reputation as one of Europe’s most egalitarian countries. It’s changed over the past two decades
Practice

When taxpayer relief, CPP limitation periods, and procedural finality abandon fairness without a remedy

Tolley v The King is a reminder that developments after tax reassessments, no matter how convincing, cannot alter relief from reassessments retroactively.
Thought Leaders

As Alberta separatists court the U.S., prosperity is fuelling a sovereigntist turn

The separatist movement and its grievance politics ignore the poor choices Alberta itself has made in terms of taxation, royalties and economic investment
Thought Leaders

Modernizing the GST/HST small-supplier threshold: A compliance fix hiding in plain sight

The issue is not whether GST/HST should exist. It’s whether the threshold governing its application still reflects sound administration in today’s economy
Practice

Superstars, Steroids and Succession

Enhancing a succession plan using Succession Enhancers is like hitting a grand slam without any controversy involved, says Matthew Getzler of Torkin Manes LLP
Practice

When CRA employees misbehave and make mistakes against Canadian taxpayers

The Canada Revenue Agency distinguishes clearly between employee misconduct and wrongdoing, applying different legal and administrative frameworks to each
Practice

CRA introduces software-specific controls for EFILE accounts, a safety feature, starting in 2026

Proactively reviewing EFILE accounts, certified tax software usage, and internal controls will position you far better when the new CRA rules take effect
Business

The world's first carbon border-adjusted tax enters its definitive phase: What it means for Canada

Rambod Behboodi and Owen Clarke of BLG explain why Canadian companies should take immediate steps to establish necessary emissions tracking regimes
Business

Alberta: Data reveals millions in tax arrears and unpaid leases for nearly 600 Alberta oil and gas companies

As of the end of 2024, property tax debt has grown to nearly $254 million, despite policies to stop deadbeat companies from acquiring new oil and gas wells
Practice

When judicial review (Federal Court) finds that interest imposed by CBSA must be waived

The decision in Lufthansa Technik Aktiengesellschaft offers guidance on how interest-relief applications must be evaluated under s. 3.3 of the Customs Act
Municipal

Patrick Brown’s 2026 budget lacks key investments as his previous spending freezes catch up to taxpayers

Debt balloons, projects shelved in the Brampton municipal budget after years of budget freezes as property taxpayers face a hike of just under five per cent
Thought Leaders

Filing taxes for someone else? Here’s how to do it safely

An academic study reveals that informal tax preparers — friends and family, not professional accountants — are not using the Canada Revenue Agency’s RepID
Practice

Top 5 need-to-know Canadian GST/HST cases from 2025

Simon Douville, Al-Nawaz Nanji and Randy Schwartz of McCarthy Tétrault on the top five from LBL Holdings to an AirBNB condo sale, from the FCA to Tax Court
Thought Leaders

What’s missing from the Davos agenda: taxing the rich

New polling shows that taxing the wealthy maintains majority support, even among the wealthy themselves. That should be reflected in international priorities
Practice

Case Commentary: HMK v. Quebecor Inc – Federal Court Of Appeal rejects GAAR challenge to using strategy of business losses

The FCA decision reaffirmed that tax efficiency alone does not equate to abuse under GAAR, explains Canadian tax lawyer and accountant David J Rotfleisch
Business

CEO pay at record highs as workers struggle to make ends meet: report

To reign in some of the wage disparity, a report from the Canadian Centre for Policy Alternatives offers two solutions: a millionaire tax and a wealth tax