National

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
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
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
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.
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
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
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

Why is the CRA still targeting pandemic aid recipients?

Continued collection attempts against people who received pandemic benefits shows a punitive logic that doesn’t fit the scale of the alleged transgressions
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