Taxation
Thought Leaders
CRA applying GAAR for outside/inside ACB misalignment on 55(3)(a) transactions
In the final part of a three-part series, Doug S. Ewens and Kenneth Keung of Moodys Tax Law ask whether the CRA is over-reaching on the scope of the GAAR
Thought Leaders
Our response to the CRA's position on creditor-proofing reorganizations – part 2 (a case study)
A three-part series from Doug S. Ewens and Kenneth Keung of Moodys Tax Law
Practice
What can a taxpayer do if a CRA decision letter is unclear?
Canadian accountant and tax lawyer David J Rotfleisch on a recent Federal Court decision against Canada Revenue Agency
Practice
When to file (and when not to file) a service complaint against the CRA
Pierre Alary of Gowling WLG on factors that support the filing of a service complaint as part of an ongoing tax dispute
Practice
Pandora Papers: More smoke than fire? CRA VDP operations manual: Top 10 takeaways
Stevan Novoselac and John A. Sorensen of Gowling WLG on the nuances of the CRA's VDP Operations Manual
Practice
Rectification and the vanishing prospects for common sense and compassion
John Sorenson of Gowling WLG asks whether the Glenmac decision demonstrates a tax system that is just, equitable and fair
Thought Leaders
The Pandora Papers: How punishing tax cheats can serve as a deterrent
Punishing tax evasion enablers could also compel taxpayers to comply with tax laws, says Professor Tisha King, CPA, CGA
Thought Leaders
A Canadian tax lawyer's scary taxes for Halloween
From Halloween candy to the Halloween Massacre, David Rotfleisch on the tricks and treats of recent Canadian tax history
Thought Leaders
The Ancient Art Of Taxation
Vern Krishna, FCPA, FCGA on the history of taxation around the world, from ancient Mesopotamia to modern-day Canada
Practice
Analysis: Tax litigants may amend their arguments during a trial
Canadian tax lawyer and accountant David J Rotfleisch analyzes Canada v. Pomeroy Acquireco
Thought Leaders
Will the OECD eliminate corporate tax avoidance? We’ll see
Allan Lanthier analyzes the most sweeping overhaul of global tax rules in more than a century
Thought Leaders
Pandora Papers: “It’s time to pursue lawyers and accountants who enable tax evasion” – offshore tax expert Q&A
Professor Ronan Palan on the repercussions of the Pandora Papers