Taxation

Practice

A sad story about Mr. X. from country Y

Canadians are deemed guilty in an unfair tax system, says Tax Lawyer Dale Barrett
Practice

Hamad v. The Queen

Canadian tax lawyer and accountant David Rotfleisch on due diligence In director liability for taxes
Thought Leaders

France-US skirmish over Amazon digital tax

Shows why the century-old international tax system is broken, says Professor Ruth Mason
Practice

Paletta et al v. the Queen, case study

Was a big Hollywood movie investment deal just make-believe?
Practice

20 tax audit triggers

The more risk factors a taxpayer has, the greater the odds of being audited
Business

No Canadians detained in Central American tax evasion bust

Canada Revenue Agency to review files for Canadian connections
Practice

A Tale Of Two Taxpayers: Parts I and II

The Tax Court is not a court of equity, says Tax Lawyer Dale Barrett
Business

Tax Law Analysis: Recent CRA guideline regarding cryptocurrency

Tax laywer and accountant David J. Rotfleisch on how the CRA sees cryptocurrencies
Practice

Bakorp Management: A milestone case for Canadian income tax law

Part I, Bakorp Management Ltd. v. Her Majesty The Queen: Choice of venue matters
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