David J. Rotfleisch
Tax Law
Recent Blog Posts By David J. Rotfleisch
Barrs v The Queen: Taxpayer relief under S.220(3.1)
Canadian accountant and tax lawyer David J Rotfleisch on a Federal Court of Appeal case involving a CRA's review officer's failure to engage with a request for equitable treatment
MNR v Zhao: CRA collection action when there are reasonable grounds for delay
Canadian accountant and tax lawyer David J Rotfleisch on the Canada Revenue Agency’s successful jeopardy order in a high-profile BC real estate case
Tax pipeline planning: A Canadian tax lawyer's guide and case study
A pipeline plan is a tool used to avoid paying tax on dividends to pay tax on capital gains explains David J Rotfleisch
FCA overturns Tax Court's decision because the CRA's evidence was about the taxpayer’s spouse
Canadian accountant and tax lawyer David J. Rotfleisch on the Khanna v The Queen decision by the Federal Court of Appeal, which overturned a Tax Court ruling
The Queen v Paletta – The legal test for business income
Tax lawyer and accountant David J. Rotfleisch on the CRA's successful appeal of a Tax Court of Canada ruling regarding foreign currency trading
Zvilna v. The Queen: Director's liability for unpaid taxes, a note of caution to directors
Tax lawyer and accountant David J. Rotfleisch on the successful appeal of a director’s liability assessment before the Tax Court of Canada
Transferring cryptocurrency to a bare trustee or holding cryptocurrency as a bare trustee
Tax lawyer and accountant David Rotfleisch on Canadian cryptocurrency tax planning through the use of bare trusts
A Canadian tax lawyer's guide on net worth assessments – Halls v The Queen, 2022 TCC 14
Canadian accountant and tax lawyer David Rotfleisch on a net worth assessment win for the CRA involving a taxpayer's record keeping
How to use BVI or other offshore non-CCPCs to save tax on investment income
Canadian tax lawyer and accountant David Rotfleisch the risks (and rewards) of the British Virgin Islands tax avoidance strategy
A Canadian tax lawyer's perspective on income tax statute-barred periods
David J Rotfleisch on the timing legalities of reassessments
A Canadian tax lawyer's perspective on Tax Court of Canada minutes of settlement vs. consent to judgment
David J Rotfleisch on settling a dispute prior to a hearing in Tax Court
RRSP double taxation from overcontribution
Tax lawyer and accountant David J Rotfleisch on double taxation and relief
Reeves v the Queen & applicability of the GST/HST new housing rebate
Tax lawyer and accountant David J Rotfleisch on why a homebuyer was denied the new housing rebate by the Tax Court of Canada
Tax Court rules that gift of shares of a private corporation to a foundation was ineligible for a charitable tax credit
Tax lawyer and accountant David J Rotfleisch on gifting non-qualifying securities such as a promissory note to a registered charity
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
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
Analysis: Tax litigants may amend their arguments during a trial
Canadian tax lawyer and accountant David J Rotfleisch analyzes Canada v. Pomeroy Acquireco
Canadian income tax - proposed First Home Savings Account
David J Rotfleisch on the Liberals' proposed tax favoured savings account
Dale et al. v the Queen – Timing on issue of shares in Section 85 rollover
Tax lawyer and accountant David J. Rotfleisch on a successful appeal of a Tax Court decision
Contesting a will in Ontario: Canadian tax lawyer guide
Provincial legislations are carefully crafted to include provisions that infringe upon and restrict an individual's testamentary freedom, says tax lawyer and accountant David J Rotfleisch
Electing out of spousal rollover on death
Toronto Tax Lawyer and Accountant David J Rotfleisch explains when, with proper estate planning, it is possible to achieve a substantially better tax outcome
Tax Clearance Certificates: Canadian Tax Lawyer Guidance
Tax clearance certificates can be beneficial but may also trigger scrutiny from the Canada Revenue Agency. Canadian tax lawyer and accountant David J Rotfleisch explains
Voluntary Disclosure Applications: Canadian Tax Lawyer's Guide
Canadian tax lawyer and accountant David Rotfleisch looks at a recent Federal Court ruling on voluntary disclosure (4053893 Canada Inc.)
Tax Court won't uphold gross-negligence penalties: Taxpayer not aware of accountant errors
Canadian tax lawyer and accountant David Rotfleisch explains the case of Frank-Fort Construction in the Tax Court of Canada
Alberta Court rejects CRA's duty of care to taxpayers
David Rotfleisch explains the Signal Hill Manufacturing case and duty of care