Practice

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
Practice

CRA real estate tax audits using MLS data: Builder risk, GST/HST exposure & audit defence strategies In Canada

In one year alone, more than 2,200 GST/HST tax audits specifically targeting housing transactions resulted in approximately $231 million in tax assessments
Practice

10 Canadian tax facts you ought to know

With the recent release of Canadian Tax Facts 2026 from David J Rotfleisch, now is the time to test your knowledge and assumptions about Canadian taxation
Practice

How to avoid the 'tax trap' on timing of flow-through for dividend income and timing of receipts for trusts

Canadian tax lawyer and accountant David J Rotfleisch examines the FCA decision in Vefghi Holding Corp. v. Canada, currently under leave to appeal at the SCC
Practice

A taxing situation: Can Canadian tech contractors working for U.S. or overseas companies incorporate?

Aron Grusko and Nick Noonan of Fillmore Riley LLP explore the tax and legal considerations of incorporation for professionals in Canada working remotely
Business

CRA may apply 2025 permanent establishment OECD rules to Canada

Canadian tax lawyer and accountant David J Rotfleisch on remote work, corporate authority to bind, CRA treaty interpretation and interprovincial tax risk
Profession

CPAB Annual Report: As transparency improves, so does audit quality at Canadian accounting firms

The Canadian Public Accountability Board reports a second consecutive year of improvement in audit firm inspection findings compared to historical results
Practice

Contempt of court in Canadian tax litigation is a high bar in Canada

The MNR v Carflex decision illustrates the high evidentiary threshold that must be satisfied before a taxpayer or corporate officer can be found in contempt
Profession

Sunday News Roundup 26.03.22: KPMG audit deficiencies, Deloitte AI errors, and more Canadian accounting news

Our weekly Canadian accounting news roundup includes CPAB audit inspection reports, why you should join CPA Canada, the accounting dealbook and more.
Practice

Unpaid payroll deductions: Federal Court Of Appeal affirms bona fide purchaser defence for unsecured creditors

Toronto-Dominion Bank v. Canada confirms that innocent unsecured creditors are not automatically liable to repay unremitted payroll deductions to the Crown