Taxation

Profession

Sunday News Roundup 24.03.03 Mulroney legacy, PwC sole source, RPA rising, and more Canadian accounting news

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

Sunday News Roundup 24.02.25: Manning Elliott, Aphria ruling, sustainability standards and more Canadian accounting news

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

Sunday News Roundup 24.02.18: Fairfax’s financials, new trust rules and more Canadian accounting news

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

The General Anti-Avoidance Rule may be expanding: What you need to know

Aron Grusko and Nick Noonan of Fillmore Riley LLP say recent legislative changes and Supreme Court decisions reflect an increasingly expansive view of GAAR
Practice

Case Commentary: Csak v The King 2024 TCC – transfers of property while owing taxes to the CRA

David J Rotfleisch explains why the Tax Court of Canada found the Canada Revenue Agency's 1988 and 1989 reassessments statue-barred
Practice

Taxpayer sidesteps gross-negligence penalties and $90,000 in taxable income because tax year was statute-barred

As David J Rotfleisch explains, the decision by the Tax Court of Canada in Abbass V The King centred on a bookkeeping error by the taxpayer's accountant
Practice

Director held personally liable for unremitted and uncollected GST/HST — due diligence defence judged insufficient

Case commentary from Canadian tax accountant and lawyer David J Rotfleisch on the Tax Court of Canada decision in Hall v The King
Practice

Case Commentary: CRA violates procedural fairness for CERB/CRB claims

Canadian tax lawyer and accountant David J Rotfleisch examines the Federal Court decision in Cameron v. Canada (Attorney General) in favour of the taxpayer
Career

Empowering CPAs: The Role of a Master’s Degree in Tax Law

Two chartered professional accountants share their insights into the Osgoode Professional LLM
Practice

Made a mistake on your tax return? Here's how to change your Canadian tax return through the tax objections process

Canadian tax lawyer and accountant David J Rotfleisch explains the legal history behind the tax objections process but cautions against aggressive tax strategies
Practice

Intergenerational business transfer rules are changing in 2024

Kenneth Keung and Jason Lau of Moodys Private Client Law say tax practitioners will need to ensure they have a full understanding of new IBT rules
Practice

A new era for the Canadian GAAR

Pooja Mihailovich and Leandra Gupta of Osler, Hoskin & Harcourt LLP say the new era may compound uncertainties and add to compliance and dispute costs
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
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
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
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
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
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