David J. Rotfleisch
Tax Law

David J. Rotfleisch, CPA, CA, JD, is the founding Canadian tax lawyer of Rotfleisch & Samulovitch, P.C., a Toronto-based boutique income tax law firm (Taxpage.com). With over 30 years of experience as both a lawyer and chartered professional accountant, he has helped start-up businesses, resident and non-resident business owners and corporations with their tax planning, with will and estate planning, voluntary disclosures and tax dispute resolution including tax litigation. Contact David at david@taxpage.com.
Recent Blog Posts By David J. Rotfleisch

The tax implications of condo flipping
The primary issue for condo flippers is categorization, says David Rotfleisch
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Insight: Treaties impacting on taxation
A primer from David Rotfleisch on bilateral tax agreements
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Why taxpayers cannot rely on advice from the CRA
Taxpayer reassessed for acting on information given to him by the CRA
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Director dodges vicarious tax liability by proving resignation
Singh v The Queen (2019 TCC 120)
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Corporate amalgamation deemed an avoidance transaction
David J. Rotfleisch looks at Birchcliff Energy Ltd. v. The Queen
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A caution to Canadian tax planners: Eyeball Networks Inc. v The Queen
A Butterfly reorganization might trigger derivative tax liability
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A taxpayer need not answer questions during a CRA tax audit
The CRA's response to a Federal Court Of Appeal decision
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Recent tightening of the Voluntary Disclosures Program
The Canada Revenue Agency's VDP and the Gauthier decision
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CRA woeful disregard for taxpayer rights
Tax lawyer David Rotfleisch on latest Canada Revenue Agency communique
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When can the CRA advance an alternative argument?
Subsection 152(9) of the Income Tax Act tips litigation in favour of the Crown
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A taxpayer's rights to interest from the Canada Revenue Agency
A case comment on Glatt v Canada (National Revenue)
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The CRA's ability to compel confidential reports
EY Canada, Atlas Tube Canada and the CRA's power to compel disclosure
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Thoughts on the CRA and Canadian corporate tax gap
Are the numbers to be trusted? asks David J. Rotfleisch
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Is crypto-currency trading exempt from GST/HST?
David J Rotfleisch on crypto-currency trading and the obligation to collect GST/HST
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What the media missed in the Auditor General’s CRA report
Canada Revenue Agency does not accurately measure its performance
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Is the CRA’s public shaming an effective deterrent of tax evasion?
The CRA is sending a clear message that tax evasion does not pay, says David J. Rotfleisch
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Auditor General slams CRA for unfair treatment of taxpayers
Michael Ferguson finds the CRA unable to measure its own activities
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Aitchison: A distasteful but correct Tax Court decision
The Canada Revenue Agency tried to fit a square peg into a round hole
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Federal Court upholds CRA audit powers
Charter Challenge: Campbell v Attorney General of Canada, 2018 FC 683
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Fighting the Canada Revenue Agency no longer like fighting city hall
The Ludmer decision represents a judicial thawing of CRA liability
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U.S. tax ruling means winter is coming for online retailers
Tax rulings are catching up with the Amazons of retail
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Multiple taxpayers successfully sue the Canada Revenue Agency
Damages in negligence: Ludmer et al c. Attorney General Of Canada
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Voluntary Disclosures Program under continued attack from Canada Revenue Agency
VDP changes are headed to the courts, predicts tax lawyer David J. Rotfleisch
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The reasonable minimum standard when challenging CRA tax audits
A look at the leading case and subsequent case law
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CRA discipline statistics shockingly low for number of service complaints
Tax lawyer David Rotfleisch says taxpayer abuse should be disciplined as well
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