Taxation

Practice

I lost my battle with the CRA, but I won the war

Taxpayers often lose at the objection stage, says Tax Lawyer Dale Barrett
Practice

Friedman: The conflict between CRA civil audits and the Canadian Charter

David Rotfleisch looks at Canada (National Revenue) v. Friedman
Thought Leaders

Canada: A brief overview of tax history

Canadian calls for tax reform have been met with minimal success
Thought Leaders

The nature of taxes

Vern Krishna, FCGA, FCPA, CM, QC looks at taxation historically and in Canada
Thought Leaders

Tax Reform: Less talk and more action, please

Ultimately, all tax law is a compromise of competing values, says Vern Krishna
Profession

Canadian tax issues involving the concept of agency

Three examples as an introduction to Canadian tax issues involving agency
Business

The tax implications of condo flipping

The primary issue for condo flippers is categorization, says David Rotfleisch
Practice

Why successful investors should worry about the CRA coming after their TFSAs

Stevan Novoselac and Reea Galeano of Gowling WLG on warrants
Taxation

Rectification strikes back: B.C. Court Of Appeal allows rectification of tax mistake

BC Court of Appeal upholds rectification of miscalculated capital dividend account
Taxation

Insight: Treaties impacting on taxation

A primer from David Rotfleisch on bilateral tax agreements
Practice

Why taxpayers cannot rely on advice from the CRA

Taxpayer reassessed for acting on information given to him by the CRA
Management

Director dodges vicarious tax liability by proving resignation

Singh v The Queen (2019 TCC 120)
Practice

Election & Taxation: Minority is the new majority

Three things everyone needs to know about the 2019 federal election
Practice

Corporate amalgamation deemed an avoidance transaction

David J. Rotfleisch looks at Birchcliff Energy Ltd. v. The Queen
Practice

Misrepresentation of business expenses exposes taxpayer to reassessment beyond normal reassessment period

Strum v. The Queen 2019 TCC 167
Business

Election 2019: The "Netflix Tax" May Be Hiding In Plain Sight

The Netflix tax has proved to be the ultimate public policy Rorschach Test, says Stephen Zolf
Thought Leaders

The economic illusions of the Canadian election

Party platforms should reflect some modicum of economic literacy, says Gregory C. Mason
Practice

A caution to Canadian tax planners: Eyeball Networks Inc. v The Queen

A Butterfly reorganization might trigger derivative tax liability
Practice

Supreme Court of Canada dismisses Samaroo CRA appeal

End of controversial tax case disappoints Canadian accountants
Practice

Notice Of Assessment: Should You Pay In Advance?

A recent court ruling provides guidance, says Jonathan Éthier of law firm Spiegel Sohmer.
Thought Leaders

How multinationals continue to avoid paying hundreds of billions of dollars in tax

New research says countries losing US$125b in tax revenue
Practice

Moore v. The Queen: Taxpayer Relief, T1135

Taxpayers may mitigate late filing penalties in some circumstances
Thought Leaders

What election tax promises will mean for your wallet

None of the tax tinkering represents bold policy, says Economist Gregory C. Mason
Practice

A taxpayer need not answer questions during a CRA tax audit

The CRA's response to a Federal Court Of Appeal decision
Practice

Recent tightening of the Voluntary Disclosures Program

The Canada Revenue Agency's VDP and the Gauthier decision