Taxation

Practice

1074022 B.C. Ltd. v. Li: The need for legislative reform

A misinterpretation of section 116 of the Income Tax Act in a BC real estate case
Profession

Coronavirus tax relief: Finally some good news for accountants

Sole practitioners, small firms will benefit most from deadline extensions
Profession

CRA further circumscribes trust 21-year planning strategies involving non-resident beneficiaries

The CRA's stated positions will result in a chill on tax practitioners' advice to their clients, says Stephen Sweeney of Miller Thomson
Practice

Scott v The Queen: The importance of evidence

How two brothers came under the scrutiny of the Tax Court of Canada
Thought Leaders

Inheritance tax, wealth tax and more capital gains tax: The future of Canadian taxation?

Canadian tax policy has become a hotbed of new ideas, writes Margaret O'Sullivan
Practice

Donor Beware: The pitfalls of participating in a donation tax shelter

The Tax Court of Canada case Abreo v. The Queen
Thought Leaders

Ottawa should forget about limiting interest expense deductibility

Allan Lanthier on the OECD's proposal to limit excessive debt leveraging
Thought Leaders

Carbon pricing may be overrated, if history is any indication

History proves radical technological change can be achieved by state intervention
Practice

The case of Muir v The Queen

Tax Court of Canada allows appeal over a section 160 assessment by the CRA
Practice

A sad story about Mr. X. from country Y

Canadians are deemed guilty in an unfair tax system, says Tax Lawyer Dale Barrett
Practice

Hamad v. The Queen

Canadian tax lawyer and accountant David Rotfleisch on due diligence In director liability for taxes
Thought Leaders

France-US skirmish over Amazon digital tax

Shows why the century-old international tax system is broken, says Professor Ruth Mason
Practice

Paletta et al v. the Queen, case study

Was a big Hollywood movie investment deal just make-believe?
Practice

20 tax audit triggers

The more risk factors a taxpayer has, the greater the odds of being audited
Business

No Canadians detained in Central American tax evasion bust

Canada Revenue Agency to review files for Canadian connections
Practice

A Tale Of Two Taxpayers: Parts I and II

The Tax Court is not a court of equity, says Tax Lawyer Dale Barrett
Business

Tax Law Analysis: Recent CRA guideline regarding cryptocurrency

Tax laywer and accountant David J. Rotfleisch on how the CRA sees cryptocurrencies
Practice

Bakorp Management: A milestone case for Canadian income tax law

Part I, Bakorp Management Ltd. v. Her Majesty The Queen: Choice of venue matters
Practice

I lost my battle with the CRA, but I won the war

Taxpayers often lose at the objection stage, says Tax Lawyer Dale Barrett
Practice

Friedman: The conflict between CRA civil audits and the Canadian Charter

David Rotfleisch looks at Canada (National Revenue) v. Friedman
Thought Leaders

Canada: A brief overview of tax history

Canadian calls for tax reform have been met with minimal success
Thought Leaders

The nature of taxes

Vern Krishna, FCGA, FCPA, CM, QC looks at taxation historically and in Canada
Thought Leaders

Tax Reform: Less talk and more action, please

Ultimately, all tax law is a compromise of competing values, says Vern Krishna
Profession

Canadian tax issues involving the concept of agency

Three examples as an introduction to Canadian tax issues involving agency
Business

The tax implications of condo flipping

The primary issue for condo flippers is categorization, says David Rotfleisch