Taxation

Practice

How to use BVI or other offshore non-CCPCs to save tax on investment income

Canadian tax lawyer and accountant David Rotfleisch the risks (and rewards) of the British Virgin Islands tax avoidance strategy
Profession

Sunday News Roundup 22.02.20: Emergency Act, crypto accounting lawsuit, cutting taxes and more 

Wrapping up the odds and ends in this week’s Canadian accounting news
Business

You Can Hide … But CRA Will Find You

Timothy Dunn of Minden Gross LLP on why the CRA may be coming after lenders, creditors and owners of struggling businesses
Thought Leaders

Twelve rules that protect the tax collector

Taxpayers have minimal procedural rights says Vern Krishna of TaxChambers LLP
Profession

Sunday News Roundup 22.02.06: O’Toole accounting, tax hawks, schwing and more 

Wrapping up the odds and ends in this week’s Canadian accounting news
Thought Leaders

The Robillard decision:  The uncertain world of death and taxes

Allan Lanthier on confusion in surplus stripping and the post-mortem pipeline, due to a recent Tax Court of Canada decision
Practice

A Canadian tax lawyer's perspective on income tax statute-barred periods

David J Rotfleisch on the timing legalities of reassessments
Practice

A Canadian tax lawyer's perspective on Tax Court of Canada minutes of settlement vs. consent to judgment

David J Rotfleisch on settling a dispute prior to a hearing in Tax Court
Practice

Avoiding the pitfalls of partnerships when making SR&ED claims

Partnerships participating in the SR&ED program may find the process to be significantly more complex compared with normal corporations
Business

Sunday News Roundup 22.01.23: Omicron blues, green taxation, anti-vax tax, and more 

Wrapping up the odds and ends in this week’s Canadian accounting news
Thought Leaders

The latest Canadian tax scam has a Caribbean flavour

Allan Lanthier looks at the BVI Switch tax avoidance scheme used by wealthy Canadians and what action could be taken by the federal finance minister
Thought Leaders

The irony behind Québec’s proposed health tax 

Fred O'Riordan, National Leader of Tax Policy at EY Canada, on whether Quebec's health tax on the unvaccinated can "move the needle"
Practice

RRSP double taxation from overcontribution

Tax lawyer and accountant David J Rotfleisch on double taxation and relief
Practice

Reeves v the Queen & applicability of the GST/HST new housing rebate

Tax lawyer and accountant David J Rotfleisch on why a homebuyer was denied the new housing rebate by the Tax Court of Canada
Thought Leaders

Alta Energy: Has the GAAR become toothless? – Part II

In part two of his two-part series, Allan Lanthier highlights areas of the Supreme Court's Alta Energy decision that are open to vigorous debate
Thought Leaders

Alta Energy: Has the GAAR become toothless? – Part I

In part one of a two-part series, Allan Lanthier looks at the details of the Alta Energy tax avoidance decision by the Supreme Court of Canada
Thought Leaders

The Canadian Taxpayers Federation’s politics are anti-Indigenous — so why do media outlets still quote them?

Canadian journalists should be wary of groups like the CTF, says Sociology Professor Kyle Willmott
Management

Using losses in a corporate group: An overview of loss consolidation

Brian Nichols and Kelsey Horning of GSNH on loss consolidation arrangements
Profession

Sunday News Roundup 21.12.12: Fiscal anchors, full of beans, Alta opinions, and more 

Wrapping up the odds and ends in this week’s Canadian accounting news
Practice

Tax Court rules that gift of shares of a private corporation to a foundation was ineligible for a charitable tax credit

Tax lawyer and accountant David J Rotfleisch on gifting non-qualifying securities such as a promissory note to a registered charity
Thought Leaders

CRA applying GAAR for outside/inside ACB misalignment on 55(3)(a) transactions

In the final part of a three-part series, Doug S. Ewens and Kenneth Keung of Moodys Tax Law ask whether the CRA is over-reaching on the scope of the GAAR
Thought Leaders

Our response to the CRA's position on creditor-proofing reorganizations – part 2 (a case study)

A three-part series from Doug S. Ewens and Kenneth Keung of Moodys Tax Law
Practice

What can a taxpayer do if a CRA decision letter is unclear?

Canadian accountant and tax lawyer David J Rotfleisch on a recent Federal Court decision against Canada Revenue Agency
Practice

When to file (and when not to file) a service complaint against the CRA

Pierre Alary of Gowling WLG on factors that support the filing of a service complaint as part of an ongoing tax dispute
Practice

Pandora Papers: More smoke than fire? CRA VDP operations manual: Top 10 takeaways

Stevan Novoselac and John A. Sorensen of Gowling WLG on the nuances of the CRA's VDP Operations Manual