Practice
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
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Profession
Big Four accounting firm Deloitte Canada comes out on top in first firm-specific inspection reports from audit watchdog
KPMG Canada has highest rate of files with significant findings among Big Four firms according to reports published by Canadian Public Accountability Board
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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
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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