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Searching Content indexed under Tax by Rotfleisch & Samulovitch P.C. ordered by Published Date Descending.
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1
Income Tax For Canadians Working At Sea – A Canadian Tax Lawyer's Perspective
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.
Canada
26 Aug 2019
2
When Can The CRA Advance An Alternative Argument? A Toronto Tax Lawyer Analysis Of Subsection 152(9) Of The Income Tax Act
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.
Canada
20 Aug 2019
3
A Canadian Tax Lawyer's Perspective On Emigration Tax Issues
Emigrating from Canada has a multitude of tax implications including which country can tax particular income and the Canadian tax owed for emigrating.
Canada
20 Aug 2019
4
Case Comment – Glatt v Canada (National Revenue) ("Glatt")
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.
Canada
20 Aug 2019
5
A Taxpayer Need Not Answer Questions During A CRA Tax Audit: Minister Of National Revenue v Cameco Corporation, 2019 FCA 67
MNR v Cameco Corporation (2019 FCA 67) shows that the Canada Revenue Agency's tax-audit powers—while broad—come with limits.
Canada
20 Aug 2019
6
Canada Revenue Agency Expands Eligibility For The Claiming Of ITCs By Holding Companies – Canadian Tax Lawyer Analysis
When a taxpayer carries on a commercial activity it inevitably incurs the additional expense of GST/HST payable on its supplies.
Canada
8 Aug 2019
7
Gordon Et Al v The Queen – Canadian Tax Lawyer's Analysis And Comments
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.
Canada
6 Aug 2019
8
Subsection 55(2): The New "Purpose" Test - A Canadian Tax Lawyer's Analysis
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.
Canada
6 Aug 2019
9
Uber Canada Inc. And The Canada Revenue Agency Settle $600,000 GST/HST Bill In Uber's Favor – A Canadian Tax Lawyer's Analysis
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.
Canada
25 Jul 2019
10
What Are The Impacts Of Canada Revenue Agency's Cap On Stock Option Tax Deductions? A Canadian Tax Lawyer's Analysis
The government budget in 2019 revealed that Canada intends to cap stock option deductions for individuals because the stock option tax deduction was regressive.
Canada
25 Jul 2019
11
Canada (National Revenue) v Atlas Tube Canada ULC – CRA Ability To Compel Confidential Reports-Canadian Tax Lawyer's Analysis And Comments
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.
Canada
18 Jul 2019
12
Daniel Laplante v The Queen – Canadian Tax Lawyer's Analysis And Comments
A Trust is a vehicle for holding family property and it's typically used to reduce a family's taxes.
Canada
4 Jul 2019
13
Ontario Nominee Exemption – Ontario Non-Resident Speculation Tax – Toronto Tax Lawyer Guide
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.
Canada
4 Jul 2019
14
Case Comment – MNR v Roofmart Ontario Inc. ("Roofmart")
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.
Canada
4 Jul 2019
15
Henson Trusts: Supreme Court Clarifies And Approves
A Henson trust is a type of trust that is settled for the purpose of benefitting a person with disabilities.
Canada
4 Jul 2019
16
Can The CRA Pursue The Beneficiary Of Your Life Insurance Under Section 160 Of The Income Tax Act? A Canadian Tax Lawyer's Analysis
Section 160 of the Income Tax Act broadens the Canada Revenue Agency's power to collect on income-tax debt.
Canada
28 Jun 2019
17
Canadian Snowbirds Should Know These US Tax Residence Rules – Tips from A Canadian Tax Lawyer
If none of the factors are conclusive which is a very rare situation, you must ask the competent authority of each country to make a decision.
Canada
18 Jun 2019
18
What Happens When A TFSA Holder Dies? – A Canadian Tax Lawyer's Analysis
Generally, when a taxpayer dies, his or her TFSA ceases to exist.
Canada
18 Jun 2019
19
Self-Represented Taxpayer Has Case Dismissed Before Hearing At Federal Court Of Canada – Canadian Tax Lawyer's Analysis And Comments
Lawrence Franklin Glazer recently had his Action against the CRA dismissed on a summary judgement.
Canada
18 Jun 2019
20
Failure To Remit Payroll Withholdings – Canadian Payroll Tax Obligations – Toronto Tax Lawyer Guide
Canadian employers that pay salaries, wages, or most other types of remuneration to an employee are required to withhold or deduct from each wage payment made to the employee.
Canada
24 May 2019
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