National
Practice
Selling the family business to the kids: the tax rules now require the parent to leave
The statute conditions for intergenerational business transfers are strict, writes Koby Smutylo. Here are six things to settle before the tax memo is right
- COMMENTS 13
- LIKES 149
- VIEWS 160
Business
Canada’s $1‑trillion investment push promises growth — but raises questions about who benefits
Productivity Mega Deduction: If the projected benefits do not materialize, budget deficits could increase, leaving taxpayers to ultimately foot the bill
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
Selling a business to an employee ownership trust: the tax memo can be right and the deal can still fail
The $10-million capital gains exemption is permanent. Your client's control over the company it applies to ends the afternoon he signs, explains Koby Smutylo
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
Philanthropists critical of Nakba exhibit donated $4.8M to groups later sanctioned
Canada Revenue Agency has revoked tax status of many Canadian charitable organizations academic asserts are “largely just conduits” for overseas funding
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
Federal Court sets strict Mutual Agreement Procedure (MAP) deadline in reassessment deals with Canada Revenue Agency
The FC Robinson MAP deadline ruling has implications for cross-border taxpayers, owner-managers, corporate groups, and accountants, says David J Rotfleisch
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
Notice of Assessment was never mailed? Federal Court of Appeal clarifies taxpayer must first prove non-delivery
The FCA Siam decision reinforces that taxpayers bear the burden of proving that a Notice of Assessment was not sent, and credibility plays a central role
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
Complaints about CRA rise 27% despite recent automated tax filing, call centre failures, processing delays, poor communication
Canada’s tax act is completely nuts; administrative modernization cannot succeed without legislative simplification, asserts tax lawyer David J Rotfleisch
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
Why R v Jarvis is the most important tax case for Canadian taxpayers
The 2002 Supreme Court of Canada decision presents a clear line between a CRA tax audit versus a criminal tax investigation, explains David J Rotfleisch
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
Tax Court confirms that taxpayers must provide clear instructions to apply refund balances
A recent Tax Court decision in BMLex Avocats v The King explains why a tax credit balance does not protect taxpayer from GST/HST instalment interest
- COMMENTS 13
- LIKES 149
- VIEWS 160
Thought Leaders
The OAS clawback is due for reform – but not the reform you may think
The Old Age Security Recovery Tax is not based on a pure measure of economic capacity and should be replaced with a smarter measure of economic capacity
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
When the CRA recharacterizes capital gains as business income: Happy Valley Farms, Stewart v. Canada
Canadian tax lawyer and accountant David J Rotfleisch dissects the legal framework, playbook governing Canada Revenue Agency audits, reassessments
- COMMENTS 13
- LIKES 149
- VIEWS 160
Practice
Audit watchdog inspection report reveals numbers behind continued expansion of MNP LLP
Homegrown national accounting firm shows no sign of slowing down expansion through multiple mergers with small firms and agencies across Canada in 2026
- COMMENTS 13
- LIKES 149
- VIEWS 160