Taxation

Practice

Case Commentary: Csak v The King 2024 TCC — Transfers of property while owing taxes to the CRA

David J Rotfleisch explains why the Tax Court of Canada found the Canada Revenue Agency's 1988 and 1989 reassessments statue-barred
Practice

Taxpayer sidesteps gross-negligence penalties and $90,000 in taxable income because tax year was statute-barred

As David J Rotfleisch explains, the decision by the Tax Court of Canada in Abbass V The King centred on a bookkeeping error by the taxpayer's accountant
Practice

Director held personally liable for unremitted and uncollected GST/HST — due diligence defence judged insufficient

Case commentary from Canadian tax accountant and lawyer David J Rotfleisch on the Tax Court of Canada decision in Hall v The King
Practice

Case Commentary: CRA violates procedural fairness for CERB/CRB claims

Canadian tax lawyer and accountant David J Rotfleisch examines the Federal Court decision in Cameron v. Canada (Attorney General) in favour of the taxpayer
Career

Empowering CPAs: The Role of a Master’s Degree in Tax Law

Two chartered professional accountants share their insights into the Osgoode Professional LLM
Practice

Made a mistake on your tax return? Here's how to change your Canadian tax return through the tax objections process

Canadian tax lawyer and accountant David J Rotfleisch explains the legal history behind the tax objections process but cautions against aggressive tax strategies
Practice

Intergenerational business transfer rules are changing in 2024

Kenneth Keung and Jason Lau of Moodys Private Client Law say tax practitioners will need to ensure they have a full understanding of new IBT rules
Practice

A new era for the Canadian GAAR

Pooja Mihailovich and Leandra Gupta of Osler, Hoskin & Harcourt LLP say the new era may compound uncertainties and add to compliance and dispute costs
Practice

When is it worth challenging the CRA's defective Tax Court pleadings?

Tax accountant and lawyer David J Rotfleisch reconciles the Federal Court Of Appeal's decisions in the similar but different Preston and Adboss cases
Practice

A Canadian tax lawyer explains why the ATIP process is critical to preparing for tax disputes with CRA

An Access to Information or Personal Information (ATIP) request can be a double-edged sword despite its importance to resolving tax matters
Practice

Tax complexities in dealing with the death of a spouse: ODSP and child benefits

Canadian tax lawyer and accountant David J Rotfleisch looks at the concept of ghost income in a win for the taxpayer in O'Brien v. The King
Thought Leaders

Australia has one of the weakest tax systems for redistribution among industrial nations – Stage 3 tax cuts will make it worse

Where does Canada rank on the global scale of income redistribution through taxation? Jim Stanford’s article on the gini coefficient provides answers