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

Scott v The Queen: The importance of evidence
How two brothers came under the scrutiny of the Tax Court of Canada
- COMMENTS 13
- LIKES 149
- VIEWS 160

Donor Beware: The pitfalls of participating in a donation tax shelter
The Tax Court of Canada case Abreo v. The Queen
- COMMENTS 13
- LIKES 149
- VIEWS 160

The case of Muir v The Queen
Tax Court of Canada allows appeal over a section 160 assessment by the CRA
- COMMENTS 13
- LIKES 149
- VIEWS 160

Hamad v. The Queen
Canadian tax lawyer and accountant David Rotfleisch on due diligence In director liability for taxes
- COMMENTS 13
- LIKES 149
- VIEWS 160

Tax Law Analysis: Recent CRA guideline regarding cryptocurrency
Tax laywer and accountant David J. Rotfleisch on how the CRA sees cryptocurrencies
- COMMENTS 13
- LIKES 149
- VIEWS 160

Bakorp Management: A milestone case for Canadian income tax law
Part I, Bakorp Management Ltd. v. Her Majesty The Queen: Choice of venue matters
- COMMENTS 13
- LIKES 149
- VIEWS 160

Friedman: The conflict between CRA civil audits and the Canadian Charter
David Rotfleisch looks at Canada (National Revenue) v. Friedman
- COMMENTS 13
- LIKES 149
- VIEWS 160

Canadian tax issues involving the concept of agency
Three examples as an introduction to Canadian tax issues involving agency
- COMMENTS 13
- LIKES 149
- VIEWS 160

The tax implications of condo flipping
The primary issue for condo flippers is categorization, says David Rotfleisch
- COMMENTS 13
- LIKES 149
- VIEWS 160

Insight: Treaties impacting on taxation
A primer from David Rotfleisch on bilateral tax agreements
- COMMENTS 13
- LIKES 149
- VIEWS 160

Why taxpayers cannot rely on advice from the CRA
Taxpayer reassessed for acting on information given to him by the CRA
- COMMENTS 13
- LIKES 149
- VIEWS 160

Director dodges vicarious tax liability by proving resignation
Singh v The Queen (2019 TCC 120)
- COMMENTS 13
- LIKES 149
- VIEWS 160

Corporate amalgamation deemed an avoidance transaction
David J. Rotfleisch looks at Birchcliff Energy Ltd. v. The Queen
- COMMENTS 13
- LIKES 149
- VIEWS 160

A caution to Canadian tax planners: Eyeball Networks Inc. v The Queen
A Butterfly reorganization might trigger derivative tax liability
- COMMENTS 13
- LIKES 149
- VIEWS 160

A taxpayer need not answer questions during a CRA tax audit
The CRA's response to a Federal Court Of Appeal decision
- COMMENTS 13
- LIKES 149
- VIEWS 160

Recent tightening of the Voluntary Disclosures Program
The Canada Revenue Agency's VDP and the Gauthier decision
- COMMENTS 13
- LIKES 149
- VIEWS 160

CRA woeful disregard for taxpayer rights
Tax lawyer David Rotfleisch on latest Canada Revenue Agency communique
- COMMENTS 13
- LIKES 149
- VIEWS 160

When can the CRA advance an alternative argument?
Subsection 152(9) of the Income Tax Act tips litigation in favour of the Crown
- COMMENTS 13
- LIKES 149
- VIEWS 160

A taxpayer's rights to interest from the Canada Revenue Agency
A case comment on Glatt v Canada (National Revenue)
- COMMENTS 13
- LIKES 149
- VIEWS 160

The CRA's ability to compel confidential reports
EY Canada, Atlas Tube Canada and the CRA's power to compel disclosure
- COMMENTS 13
- LIKES 149
- VIEWS 160

Thoughts on the CRA and Canadian corporate tax gap
Are the numbers to be trusted? asks David J. Rotfleisch
- COMMENTS 13
- LIKES 149
- VIEWS 160

Is crypto-currency trading exempt from GST/HST?
David J Rotfleisch on crypto-currency trading and the obligation to collect GST/HST
- COMMENTS 13
- LIKES 149
- VIEWS 160

What the media missed in the Auditor General’s CRA report
Canada Revenue Agency does not accurately measure its performance
- COMMENTS 13
- LIKES 149
- VIEWS 160

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
- COMMENTS 13
- LIKES 149
- VIEWS 160

Auditor General slams CRA for unfair treatment of taxpayers
Michael Ferguson finds the CRA unable to measure its own activities
- COMMENTS 13
- LIKES 149
- VIEWS 160