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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
In this context the term "foreign entity" means either a foreign national or a foreign corporation.
By David Rotfleisch
As we will explain, it is very important to seek proper advice and assistance from an experienced Canadian tax lawyer prior to granting a power of attorney.
By David Rotfleisch
Notably, any amount of a settlement payment for damages with respect to personal injury or death is exempt from tax.
By David Rotfleisch
The tax treatment of income varies dependent on the type of income.
By David Rotfleisch
To many people, an unlimited liability company (ULC) may sound like a contradiction in terms.
By David Rotfleisch
However, recent trends in the CRA's common practice have seen a general tightening of how the program is run.
By David Rotfleisch
This article ends by providing tax tips in light of the Cameco decision and the CRA's tax-audit policy.
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.
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