Practice

Practice

Consultation on the Regulation 105 waiver process: What business owners, service providers and practitioners need to know

Regulation 105 waiver process widely viewed as inefficient, misaligned with modern cross border business practices, says Brendan G. Ho of Miller Thomson
Practice

Forgotten, missing tax records and unreported income will cost you penalties

Karlozian serves as a cautionary example of the risks of poor record-keeping and incomplete tax reporting, says tax lawyer and accountant David J Rotfleisch
Practice

Withholding tax and beneficial ownership: C&W Offshore Ltd. v. HMK, 2026 TCC 40

A non-resident vendor’s silence on an invoice does not relieve a Canadian resident of its statutory duty to withhold and remit tax under the Income Tax Act
Municipal

NS: Pictou County council surprised by Deloitte audit and $100k+ bill

Taxpayers in tiny Maritime municipality on hook for $109K because Nova Scotia government ordered secret tax sale process audit by Big Four accounting firm
Practice

It’s almost June. When will the PCAOB publish another Canadian audit inspection report?

The American audit watchdog, defanged by Trump administration deregulation, is far behind its usual publication rate and unlikely to improve in the future
Practice

How to beat CRA alternative tax assessments: Insights from a Canadian tax lawyer

Canadian tax lawyer and accountant David J Rotfleisch presents four strategies based on recent judicial decisions to undermine these CRA tax assessments
Practice

Aggressive tax planning schemes, specially those designed by third parties, will annoy CRA – Canada v. Microbjo Properties Inc.

The Federal Court of Appeal in this case made it clear that true arm’s length dealings require independent interests, real negotiation, and genuine risk
Profession

Regulators and audit leaders discuss audit quality and confidence in Canada's financial reporting

Left to right: Stan Magidson, Canadian Securities Administrators; Peter Routledge, Superintendent, OSFI; and Sonny Randhawa, Canadian Public Accountability Board
Practice

How disobeying a Federal Court order under the Income Tax Act will result in ‘contempt of court’ charge plus fines & penalties

As David J Rotfleisch explains, the courts make a clear distinction between the inability to comply and a lack of effort, when it comes to contempt of court
Practice

When fake tax losses lead to CRA gross negligence penalties: The risk of willful taxpayer blindness

The recent McCutcheon decision reinforces a fundamental principle of Canadian tax litigation, explains Canadian tax lawyer and accountant David J Rotfleisch
Profession

Bridging Finance allegations just the latest in KPMG Canada audit quality criticism

Under new disclosure rules, Canada’s audit watchdog recently revealed that KPMG had the worst audit inspection results among the Big Four accounting firms
Practice

The meaning of HST 'included in' the purchase price for real property (after the CRA has assessed the HST)

Greg Farano of Gardiner Roberts LLP on a court case involving an HST registrant who self-assessed HST on the value of commercial portion of a sold property