David J Rotfleisch explores whether the Foix decision by the FCA radically undermines the tax benefits of a hybrid sale when selling a private business

With the economic substance wording in the general anti-avoidance rule, Finance Canada has given a present to the tax judiciary, says Raymond G. Adlington

MaryAnne Loney of McLennan Ross LLP looks at three areas of tax planning related to private corporations that will change in 2024

Canadian tax accountant and lawyer David J. Rotfleisch discusses ITFs, including tax implications, issues and alternatives to these unregistered investment accounts

Relief requests beyond the statute of limitation may still be available, depending on the circumstances, explains tax accountant and lawyer David J Rotfleisch

Laurie Goldbach and Steve Suarez of BLG on disclosure of tax planning documents and the Tax Court's treatment of accountant-client privilege

A case before the BC Supreme Court included violations of the Income Tax Act and Excise Tax Act explains Canadian accountant and lawyer David J Rotfleisch

The courts will increasingly gravitate toward the minority approach in the Deans Knight decision, assert the tax lawyers of Counter Tax Litigators

A thought leadership article on high income earners in the UK may hold some insights into Canadian attitudes towards inequality and taxation among the wealthy

Developing new recipes qualifies for Scientific Research and Experimental Development credits, explains David J Rotfleisch, when you make frozen pies

It is not the Tax Court's job to provide equitable relief, David Rotflesich explains, as the Income Tax Act provides a bright-line test for medical expense tax credits

After a decade of underfunding, the Internal Revenue Agency is receiving a cash injection, similar to the reinvestment in the CRA by the Trudeau government