National

Practice

Recent Tax Court cases on ISC business expenses

John Bassindale and Daniel Zhang of Millar Kreklewetz look at two recent Tax Court cases involving multi-level marketing and independent sales contractors
Practice

When late filing penalties apply under subsection 162(7), one's track record of respecting CRA filing deadlines matters

The recent Tax Court of Canada decision in Laurie v. the King highlights the narrow scope of the due diligence defence in regards to late-filed T1135 forms
Thought Leaders

Alternative federal budget 2026: Taxation

As the Carney government prepares to unveil its budget on Tuesday, the Canadian Centre for Policy Alternatives has presented its Alternative Federal Budget
Practice

Agreements must be in writing: Hutchings v. the King, a case of Covid-19 rent subsidies

Paper, not promises, matter when it comes to government subsidies to businesses during the pandemic, though verbal agreements are customary for some
Practice

Couture v Canada (Revenue Agency) — How not to conduct a judicial review

Federal Court applications for judicial review must include essential or minimum elements, facts or legal grounds, indicating unreasonable CRA decisions
Practice

When Canadian taxpayers have severe emotional trauma, documentation is key to taxpayer relief requests

The 2025 judicial review of Bifano v Attorney General (2019) demonstrates the need for documentation from psychologists, doctors explains David J Rotfleisch
Practice

Case Commentary: Schwarz v. HMK – You must appeal within the deadline for tax reassessments

The Tax Court of Canada cannot forgive tax debt. Its jurisdiction is limited to correctly determining the amount of tax payable explains David J Rotfleisch
Practice

Significant positive changes to reinvigorate the Voluntary Disclosures Program for income tax and GST/HST

Michael Ciomyk, Rojin Esmaeili and Zoë Sebastien of McCarthy Tétrault LLP outline changes by the CRA that seek to broaden the previously restrictive program
Practice

Case Commentary: Charlebois v. The King – How NOT to apply for GST/HST rebate for owner-built homes

The CRA can make assumptions that a home is not qualified for a rebate; it is the taxpayer's burden to refute the assumptions, explains David J Rotfleisch
Partner Posts

CPA Canada welcomes new board chair and vice-chair

Chartered Professional Accountants of Canada (CPA Canada) welcomes new leadership to its board of directors following its Annual Meeting of the Members
Practice

Does your job require you to buy luxury goods? And, can you deduct those luxury goods on your taxes?

Canadian tax lawyer and accountant David J Rotfleisch deconstructs the case of Holt Renfre employee claiming luxury clothing expenses in Samotus v. The King
Practice

PCAOB inspection report: Ernst and Young Canada lowers audit deficiency rate

EY Canada lowers deficiency rate from 50 to 25 per cent according to US audit watchdog inspection report over four 2024 audits by Big Four accounting firm