Taxation

Practice

Canadian taxpayer involved in a bad will investment scheme granted additional relief on accrued interest

Relief requests beyond the statute of limitation may still be available, depending on the circumstances, explains tax accountant and lawyer David J Rotfleisch
Practice

Court orders delivery of tax planning memo prepared by accountants to CRA

Laurie Goldbach and Steve Suarez of BLG on disclosure of tax planning documents and the Tax Court's treatment of accountant-client privilege
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
Practice

CRA's ex parte jeopardy order application must provide full and frank disclosure

Canadian tax accountant and lawyer David J Rotfleisch on a win in Federal Court in a high-profile tax case and a lack of full and frank disclosure from the CRA
Profession

Sunday News Roundup 23.08.06: CPAB auditor crackdown and more Canadian accounting news

Wrapping up the odds and ends from the past week in Canadian accounting news
Practice

Tax settlement In Canadian tax litigation: Challenges for Canadian taxpayers

Canada's courts say a CRA settlement must be principled and not a compromise, explains Canadian accountant and tax lawyer David J Rotfleisch
Practice

Sunday News Roundup 23.07.23: US tax pressure, file those T2s, and more Canadian accounting news

Wrapping up the odds and ends from the past week in Canadian accounting news
Practice

CRA to introduce new automatic tax filing system as many Canadians miss out on benefits

Tax filing and tax software groups have been actively discouraging the CRA and its U.S. equivalent, the IRS, from implementing automatic returns
Taxation

10 fun facts about taxes in Canada

Who pays more? Individuals or corporations? Is Canada a tax haven? And who is paying their fair share? We have the answers courtesy of Canadian Tax Facts
Practice

Lawyer-client confidentiality may fail to protect end-product tax documents, says FCA

The BMO Nesbitt Burns decision draws a distinction between legal advice and end-product documents says tax lawyer and accountant David J Rotfleisch
Thought Leaders

GAAR Clips Westminster’s Wings

Vern Krishna, whose work was cited in the Deans Knight decision by the Supreme Court of Canada, explains the history of the Westminster principle and GAAR
Practice

How to legitimately defer the worst of Canada's departure tax when becoming a non-resident and moving to another country

The departure tax can create a substantial and unforeseen tax bill for the unaware emigrating taxpayer explains tax lawyer and accountant David J. Rotfleisch
Thought Leaders

Alberta: Why we need to rewrite the script on corporate taxes

Corporate tax cuts did not save jobs in Alberta and wealthy people do not choose where to live based on taxes, says economics professor Junaid B. Jahangir
Profession

Sunday News Roundup 23.06.11: FCA rules on IrisTel, PwC Oz woes continue, and more Canadian accounting news

Wrapping up the odds and ends from the past week in Canadian accounting news