Taxation
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
Thought Leaders
The economic illusions of the Canadian election
Party platforms should reflect some modicum of economic literacy, says Gregory C. Mason
Practice
A caution to Canadian tax planners: Eyeball Networks Inc. v The Queen
A Butterfly reorganization might trigger derivative tax liability