Taxation

Practice

Tax fraud and tax evasion in the same case: Analysis of Regina v Reynolds

A case before the BC Supreme Court included violations of the Income Tax Act and Excise Tax Act explains Canadian accountant and lawyer David J Rotfleisch
Practice

Deans Knight will have a serious impact on tax planning & tax disputes

The courts will increasingly gravitate toward the minority approach in the Deans Knight decision, assert the tax lawyers of Counter Tax Litigators
Thought Leaders

Wealthy but worried: why the UK’s top 10% are turning their backs on the rest of society

A thought leadership article on high income earners in the UK may hold some insights into Canadian attitudes towards inequality and taxation among the wealthy
Practice

SR&ED Tax Credits upheld by Tax Court Of Canada in Canafric Inc. v. The King

Developing new recipes qualifies for Scientific Research and Experimental Development credits, explains David J Rotfleisch, when you make frozen pies
Practice

CRA routinely disallows parking expense claims, even for life-threatening illnesses

It is not the Tax Court's job to provide equitable relief, David Rotflesich explains, as the Income Tax Act provides a bright-line test for medical expense tax credits
Thought Leaders

IRS is using $60B funding boost to ramp up use of technology to collect taxes — not just hiring more enforcement agents

After a decade of underfunding, the Internal Revenue Agency is receiving a cash injection, similar to the reinvestment in the CRA by the Trudeau government
Thought Leaders

Benefits of paperless processing for taxpayers: Lessons for CRA from the IRS

Canadian taxpayers will benefit if the CRA follows the IRS in the paperless processing of income tax returns but not at the expense of customer service
Practice

Are CRA publications clear and easy to understand? Can Canadian taxpayers trust their information?

Canadian tax lawyer and accountant David J Rotfleisch explains why taxpayers should not necessarily trust CRA publications such as folios, bulletins and circulars
Practice

Government of Canada releases package of proposed domestic and international tax legislation

The tax team at Davies Ward Phillips & Vineberg LLP review August's draft tax legislation released by the Department of Finance for public consultation
Practice

Canada releases modified proposals to amend the General Anti-Avoidance Rule

Martha Macdonald, Gwen Watson and Michael Steele of Torys LLP in Toronto parse the government's August proposals to amend Canada's GAAR legislation
Practice

Standards of tax statutes and tax caselaw must be respected in reply from CRA to taxpayers

The Hillcore Financial decision by the Tax Court Of Canada shows the importance of crafting tax pleadings that follow the rules says David J Rotfleisch
Practice

Deans Knight Income Corporation v. The King – Case Study

Supreme Court's majority decision will add sustenance to the criticism that GAAR creates uncertainty for taxpayers, explains Lorne Saltman of Gardiner Roberts LLP