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Rotfleisch & Samulovitch P.C.
 
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Tel: +1 416 367 4222
Fax: +1 416 367 8649
2822 Danforth Avenue
Toronto
Ontario
M4C 1M1
Canada
By David Rotfleisch
If you are a Canadian citizen or resident working or planning to work at sea, then it may seem counterintuitive to learn that the income you earn from that job will be subject to Canadian income tax as though it was earned here in Canada.
By David Rotfleisch
During a typical tax dispute between a taxpayer and the CRA, the CRA will advance one or several grounds for the assessment or reassessment against a taxpayer.
By David Rotfleisch
Emigrating from Canada has a multitude of tax implications including which country can tax particular income and the Canadian tax owed for emigrating.
By David Rotfleisch
Under the Income Tax Act, RSC 1985, c 1 (5th Supp) ("ITA") 164(3) the CRA must refund interest at a prescribed rate based on the amount in respect of a taxation year that is refunded or repaid.
By David Rotfleisch
MNR v Cameco Corporation (2019 FCA 67) shows that the Canada Revenue Agency's tax-audit powers—while broad—come with limits.
By David Rotfleisch
When a taxpayer carries on a commercial activity it inevitably incurs the additional expense of GST/HST payable on its supplies.
By David Rotfleisch
The plaintiffs, Allan Jay Gordon, James A. Deacur and Associates Ltd. [and James Allan Deacur sought damages from the government of Canada alleging that the Canada Revenue Agency conducted tortious act in its criminal investigation.
By David Rotfleisch
Taxation of inter-corporate dividends has been expanded by amendments to Subsection 55(2) of the Income Tax Act first proposed in the 2015 Federal Budget.
By David Rotfleisch
This article looks at the tax dispute between the Canada Revenue Agency and Uber Canada Inc. Afterwards, we provide GST/HST tax tips based on the lessons we might draw from the outcome of this dispute.
By David Rotfleisch
The government budget in 2019 revealed that Canada intends to cap stock option deductions for individuals because the stock option tax deduction was regressive.
By David Rotfleisch
In Canada (National Revenue) v Atlas Tube Canada ULC, the Federal Court held that Canada Revenue Agency could compel a private corporation to disclose its draft tax due diligence report during the course of an ongoing audit.
By David Rotfleisch
A Trust is a vehicle for holding family property and it's typically used to reduce a family's taxes.
By David Rotfleisch
The Ontario non-resident speculation tax applies when real estate located in the greater golden horseshoe region in Ontario is acquired by a foreign entity or taxable trustee.
By David Rotfleisch
The CRA has general powers to require persons to provide information related to a tax audit however these general powers are limited, such that, the CRA cannot require persons to provide third party documents without judicial authorization.
By David Rotfleisch
A Henson trust is a type of trust that is settled for the purpose of benefitting a person with disabilities.
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