Tax Assistance

Rotfleisch & Samulovitch PC will soon be celebrating its 30th anniversary as a tax and corporate law boutique firm. Founding lawyer, David Rotfleisch is an expert in the realm of income tax law. You might say that income tax is David’s passion for he is not only a Canadian tax lawyer, he is a chartered professional accountant. The tax law firm focuses on income tax planning and will structure tax free reorganizations or rollovers and implement them. By understanding tax planning and how the Income Tax Act works, our tax litigation lawyers are better able to handle income tax and GST/HST litigation, fighting CRA at all levels from audit through the Tax Court and Federal Court of Canada, and we have brought a leave application to the Supreme Court of Canada.

Our Canadian law firm has helped start-up businesses, resident and non-resident business owners and corporations with their corporate and income tax affairs, and over the years, have assisted numerous corporations and individuals with simple and complex income tax, GST and will and estate planning matters as well as tax amnesty and tax litigation issues.

ADVICE CENTRE CONTENT

Rotfleisch Samulovitch PC is one of Canada's premier boutique tax law firms. Its website, taxpage.com, has a large database of original Canadian tax articles. Founding tax lawyer David J Rotfleisch, JD, CA, CPA, frequently appears in print, radio and television. Their tax lawyers deal with CRA auditors and collectors on a daily basis and carry out tax planning as well.

Rotfleisch & Samulovitch P.C.

David Rotfleisch

Nathaniel Hills

How to Deal with CRA Tax Problems

Content CRA Restaurant Tax Audits: When CRA Reconstructs Your Sales From Eggs, Pitas, And Wine

Content How CRA Treats $40M In Stolen Bitcoin Cryptocurrency: Lessons From Coinkite Coldcard Hack

Content CRA Uses ‘Alternative Methods’ For GST/HST Audits, Including Estimating Business Revenue, Reconstructing Missing Receipts

Content Missed CRA Email Notification After A Reassessment: Can You Still File A CRA Objection?

Content Notice Of Assessment Was Never Mailed? Federal Court Of Appeal Clarifies The Taxpayer MUST FIRST PROVE NON-DELIVERY In Siam V. Canada , 2026 FCA 91

Content What Triggers A CRA Audit? Here’s The List, Compiled By A 40-year Canadian Tax Lawyer

Content Tax Court Of Canada Says CRA Cannot Use ‘Fairness’ Reassessment To Immunize A Tax Increase From Appeal: A Canadian Tax Lawyer Analyzes Forrest v The King

Content How CRA’s Expanded Section 160 And Budget 2025 Supplementary Rule Closes Asset Transfer Loopholes

Content Proactive CRA Objections Strategy: A Case Study On Controlling Process Risk And Protecting Taxpayer Rights

Content Gifted A House? How Transferring Property (Cheaply) Can Also Transfer Tax Debt To Someone Else: A Comprehensive Guide To Section 160 Of The Income Tax Act

Content The Clear Line Between CRA’s Tax Audit vs. A Criminal Tax Investigation: Why R v Jarvis Is The Most Important Tax Case For Canadian Taxpayers

Content Canada’s Tax Act Is Too Complex: Complaints About CRA Rise 27% Despite Recent Automated Tax Filing, Call Centre Failures, Processing Delays, Poor Communication

Content From 4% Random Selection To 100% Audit Risk: How CRA’S AI-Driven Audits Are Changing Tax Enforcement For Canadians

Content CRA Net Worth Audit Lawyer Canada: How Taxpage.com Successfully Argued Tax Court Of Canada Appeal, Reducing Client’s CRA Tax Reassessment By $400,000+ And Eliminating Gross Negligence Penalties

Content Section 160 Cryptocurrency Tax In Canada: CRA Rules For Related-Party Crypto Transfers

Content CRA Agents Answer Only 17% Of Tax Questions Accurately: What Canadian Taxpayers Must Know About The Auditor General And Ombudsperson Reports

Content The OnlyFans Audit: Why A Canadian Tax Lawyer Warns Creators That The CRA Is Watching (For Income Tax Due)

Content Hips Don’t Lie—And Neither Do Flight Records: A Canadian Tax Lawyer On What The Shakira Case Teaches High-Net-Worth, Mobile Canadians

Content Malek v The King (2026 TCC 84): Net Worth Assessments, Gross Negligence Penalties, And The Risks Of Poor Tax Compliance In Canadian Owner-Managed Businesses

Content The $35 Billion Refund For 2025 Tax Season: Why A Canadian Tax Lawyer Says The CRA’s New Push For Digital Tax Filing Actually Worked

Content When CRA Issues A Notice Of Reassessment But Mails It To The Wrong Address, The Canadian Taxpayer Wins: Shaker v. The King, 2026 TCC 63

Content CRA Phishing Scams And CRA Impersonation Fraud In Canada: What Taxpayers Need To Know About Identity Theft And Tax Fraud

Content Burzuk v The King (2026 TCC 95): Using Shady Consultants? Why Tax Court Of Canada Applied Gross Negligence Penalties Of $350,000 For Illegal Tax Scheme That Grew To $1.3 Million Tax Bill

Content When CRA Denies Business Losses: How To Respond, Protect Your Tax Deductions, And Win Your Tax Dispute

Content CRA Denied Your Business Loss After A Tax Audit? What To Do Immediately To Challenge The Reassessment

Content CRA Delays Under Formal Investigation: Limited Remedies For Taxpayers Facing Administrative Backlogs

Content Cross-Border Businesses: CRA vs IRS Tax Authority Size, Efficiency, And Tax Enforcement

Content Can The CRA Trace Cryptocurrency? How Blockchain Analytics And AI Are Used In Canadian Crypto Tax Audits

Content How The CRA Uses Artificial Intelligence In Canadian Tax Audits: What Taxpayers Must Know Now

Content Is The CRA Using Flawed AI To Audit You? Lessons For Canadian Taxpayers From The Robodebt Scandal, An Australian Tax Disaster

Content Living Abroad? A Tax Lawyer Explains What The Shakira Tax Case Teaches Americans About Moving Wealth

Content DISOBEY A COURT ORDER UNDER CANADA’S INCOME TAX ACT? A REAL TAX LESSON FOR BUSINESSES, INDIVIDUALS: FINES, COURT COSTS, Minister Of National Revenue v. 1718743 Ontario Inc. (Sanderson Outdoor) Et Al. (2026 FC 435)

Content Forgotten, Missing Tax Records And Unreported Income Will Cost You Penalties: Canadian Tax Lawyer Analyzes The Court Case KARLOZIAN v. THE KING (2024 TCC 121)

Content How To Beat CRA Alternative Tax Assessments: Insights From A Canadian Tax Lawyer

Content CRA vs. IRS Audits: What Every Canadian Tax Lawyer Wants You To Know

Content Is The CRA Easier On You Than The IRS? A Canadian Tax Lawyer Explains Their Different Tactics, Processes

Content How Disobeying CRA Will Result In ‘Contempt Of Court’ Charge In Tax Court, Plus Fines And Other Penalties: Minister Of National Revenue v. 1718743 Ontario Inc. (Sanderson Outdoor) Et Al. (2026 FC 435)

Content Aggressive Tax Planning Schemes, Specially Those Designed By Third Parties, Will Annoy CRA – Canada v. Microbjo Properties Inc.

Content Smith v. The King – Missed The Deadline To Object To A CRA Tax Reassessment? What The Tax Court Requires To Grant An Extension Of Time

Content Gill v. The King -Transferring Property Among Family Members, When You’re In Debt To CRA? That Triggers Secondary Tax Liability (Because It Appears To Be A Tax Dodge)

Content CRA Real Estate Tax Audits Using MLS Data: Builder Risk, GST/HST Exposure & Audit Defence Strategies In Canada

Content McCutcheon v. The King – When Fake Tax Losses Lead To CRA Gross Negligence Penalties: The Risk Of Willful Taxpayer Blindness

Content 2251102 Ontario Inc. v. The King – CRA Net Worth Tax Reassessments Triggered By Taxpayer’s Bad Bookkeeping, Lack Of Receipts; CRA’s Reassessment Process Hard To Fight Against

Content Blake v. Ahmed (2025 BCCA 384): The Court Says, Bring Real Arguments, Not Organized Pseudo-Legal Commercial Arguments (OPCA) —Or Don’t Bring A Case

Content Contempt Of Court In Canadian Tax Litigation Is A High Bar In Canada: Lessons From MNR V Carflex Distribution Inc. (2025 FC)

Content Case Comment On Taxpayers’ Liability Under S.160 Of The Income Tax Act – Panneton v The King, 2019-1067(IT)G

Content CRA Service Levels 2026: Why The CRA’s 70% Call-Answering Target Is A Problem For Taxpayers

Content CRA vs. IRS Service Levels: A Cross-Border Comparison Of Tax Administration Risks For Canadian And U.S. Taxpayers

Content 'CRA Register Again’ Feature: New Self-Serve Online Access Option For Locked Or Inaccessible 'CRA My Account’ Users

Content CRA EFILE Software Block Security Enhancement

Content Accepting Money From A Spouse With Tax Problems Can Give You A Bigger Problem With CRA: Panneton v. The King (2024 TCC 24)

Content When CRA Employees Misbehave And Make Mistakes Against Canadian Taxpayers

Content CRA Introduces Software-Specific Controls For EFILE Accounts, A Safety Feature, Starting In 2026

Content What To Do When You Receive A Notice Of Non-Compliance: Advanced Strategies To Comply With A Canadian Tax Audit, Fixing Honest Tax Mistakes, Resolving CRA Audits, And Canadian Crypto Tax Challenges While Avoiding Costly CRA Penalties

Content Net-Worth Assessments, Shareholder Benefits, And Statute-Barred Years: Lessons From Afdon Contracting Ltd. v. The King 2025 TCC 175

Content How A CRA Tax Audit That Uses Bank Deposit Analysis Affects Tax Reassessments In Canadian Tax Litigation: Comparing Premier Fasteners Inc. v The King And Hickman Motors Ltd. v Canada

Content What Businesses Need To Know About Expanding Minister Of National Revenue Powers During Reassessments Under Income Tax Act, Subsection 152(9) – Perspective From Canadian Tax Lawyer

Content Be Very Afraid: The Canada Revenue Agency (CRA) Has Impressive Powers To Enforce Collection, Plus Penalties And Interest For Non-Compliance

Content When You’re In Cryptocurrency Tax Litigation With CRA Trial Strategy (Part V): Evidentiary Burden, Expert Evidence, And Credibility At The Tax Court Of Canada

Content Jennings-Clyde v. Canada (Attorney General), 2025 FCA 225 – When The CRA Denies Taxpayer Relief, It Must Explain Clear Reasons Why

Content CRA Cryptocurrency Tax Litigation Business Income vs Capital Gains (Part IV): Including CRA Tax Audits, And Tax Court Appeals

Content Cryptocurrency Tax Litigation Evidence (Part ii): Evidence, Burden Of Proof, And Managing Risk Of A CRA Tax Audit Or CRA Tax Reassessment

Content How To Handle CRA Notice Of Objection For Cryptocurrency Tax Reassessments (Part iii): Managing CRA Tax Audit Risk And CRA Tax Reassessment Exposure

Content CRA Cryptocurrency Tax Litigation (Part i): How To Handle CRA Objections, Tax Court Litigation, And More For Cryptocurrency Tax Disputes In Canada

Content Toews v. The King [2025 TCC 2024-239(IT)] – When CRA Reassesses You Beyond The Normal Period For Tax Shelters For Charitable Donations

Content A Tax Payment 2,700 Years Late Echoes CRA Backlog: Same Tax Problems Plague Assyrian Tribute And Modern Bureaucracy

Content Strict Deadlines To Apply For Time Extensions Under Section 166.2 Of The Income Tax Act – Simon Ribbans Photography Inc. v. The King (2025 TCC 146)

Content CRA Continues To Have Major Problems In Call Centres: Auditor General’s 2025 Report | Canadian Tax Lawyer Analysis

Content CRA Finally Unveils 100-Day Service Improvement Plan For 2025: How Canadian Taxpayers Should Benefit

Content Canadian Taxpayers Eagerly Await CRA’s 100-Day Service Improvement Plan To Answer More Calls With Live Humans

Content When Can You Make Changes To A Tax Return You Already Filed? Canadian Tax Lawyer Tells You What You Need To Know Before Making Changes

Content When Late Filing Penalties Apply Under Subsection 162(7) Plus Your Track Record Of Respecting CRA Filing Deadlines – Laurie v. The King (2025 TCC 130)

Content Guindon v Canada (2015 SCC 41): Landmark Supreme Court Tax Case

Content The Evolution Of Administrative Tax Penalties In Canada And Why It Matters To Canadians: From Guindon To Bozzer And Beyond

Content CRA’s Expanding Use Of Administrative Tax Penalties (2020–2025): What Canadian Taxpayers Need To Know Now

Content CRA’s Increasing Use Of Digital Tools And AI Analytics To Enforce Penalties: What Canadian Taxpayers Need To Know Now

Content The CRA Voluntary Disclosure Program: A Guide For The Canadian Taxpayer

Content What To Do When The CRA Freezes Your Bank Account: A Canadian Tax Lawyer’s Guide

Content Canadian Tax Trap: Section 160 Leads To Derivative Tax Liability For 50-50 Shareholders Who Receive Dividends From A Tax-Debtor Corporation: McCague v The King, 2025 TCC 59

Content How To Best Leverage Small Business Investment Corporations: Section 150.1(2.1) Of The Income Tax Act

Content CRA Not Providing Relevant, Clear, And Concise Information To Canadian Taxpayers: 2024-2025 Ombudsperson’s Annual Report

Content CRA Unveils New Process For Canadian Taxpayers To Authorize Their Tax Representatives To Access Their Online CRA Account Using "Authorize A Representative”

Content How CRA Conducts Net Worth Audits And Enforces Gross Negligence Penalties Against Canadian Taxpayers: Lessons From Mann v. The King And Other Cases

Content Bank Of Nova Scotia v The King – How A Procedural Rule On Loss Carrybacks Triggered $7.9M In Interest Arrears On Tax Not Owing

Content Can CRA Require A Taxpayer To Prepare Net Worth Audit Schedules Under The New Section 231.1?

Content Landmark Canadian Tax Law Decision That Limits CRA’s Authority Under Section 231.2 Of Income Tax Act: Canada (National Revenue) v Shopify Inc., 2025 FC 968

Content Case Study: How Rotfleisch & Samulovitch Helped Reduce The Tax Owed By ON Corp To CRA From $140,000 To $3,000

Content What Is The EFILE Program? Eligibility, Requirements, Obligations, And Revoking Of Registration: A Guide For Accountants & Tax Preparers

Content Tax Debt In Canada: Bankruptcy, Consumer Proposals, Uncollected Taxes, And The CRA’s Approach

Content How To Disclose Unreported Income From OnlyFans To The Canada Revenue Agency (CRA) – Here’s The Skinny From A Canadian Tax Lawyer

Content Case Commentary: The King v. Csak – Why Filing A Waiver For A Tax Reassessment Must Be Done Within The Normal Reassessment Period—or The Waiver Will Be Invalid

Content Case Commentary: Onischuk v. The King – Tax Court Rules Cannot Override CRA’s Statutory Requirements

Content Canadian Court Saves Widow From The CRA’s $100,000 Derivative Tax Assessment: A Widow Is Not A "Spouse”: Enns V Canada, 2025 FCA 14

Content Case Commentary: Yadgar v. The King – When Trusting Your Accountant 100% Is Not An Acceptable Defense In The Tax Court Of Canada

Content Who Has More Enforcement Powers? Comparing The Canada Revenue Agency (CRA) And The U.K. Tax Authority (HMRC)

Content Automatic Tax Filing For Canadian Taxpayers, Called SimpleFile, Coming In Spring 2025: Update From An Expert Canadian Tax Lawyer

Content Canadian Businesses Will Receive All Their Mail From The Canada Revenue Agency (CRA) Via The Online Portal Starting In Spring 2025: How Canadian Taxpayers And Businesses Need To Prepare

Content Taxpayer’s Failure To Review Her Tax Return Contributed To Negligence, Tax Court Of Canada Finds

Content What Are A Taxpayer’s Rights During An Access To Information And Privacy (ATIP) Request For Their Own Tax Records? Canadian Tax Lawyer Explains

Content Can CRA Issue An Assessment And Immediately Collect GST/HST? Yes, Even During An Audit

Content Fang v. AGC: Fail To Check Your CRA Online Account? Don't Know CRA's Procedures? You Could Owe Significant Tax

Content Can CRA Collect Tax On Your Foreign Assets? Yes, Tax Collection Assistance Provisions Exist Between Canada And Other Countries, Canadian Tax Lawyer Explains

Content Case Commentary: The Supreme Court Denies Income Tax Exemption To Conscientious Objectors Of Abortion (Norejko v. The King)

Content Canada Revenue Agency’s Real Estate Tax Audits Yield $2.7B In Additional Tax, Penalties

Content Complaints Continue From Canadian Taxpayers About Excessive CRA Wait Times – Despite $400 Million Boost In Funding - Are Spurring A New Probe From The Auditor General

Content Taxpayer Avoids $72,000 In Derivative Tax Liability Because The CRA Failed To Prove That Her Husband Owed The Underlying Tax: Vasilkioti V The King, 2024 TCC 101

Content Do You Have Tax Debts To CRA? Here Are 4 Situations When Taxpayer Relief May Be Possible

Content How Lower Income Individuals Can Receive Valuable Tax Benefits By Using CRA's New Free SimpleFile Program A Canadian Tax Lawyer Explains

Content Are CRA Publications Clear And Understandable? Can Canadian Taxpayers Trust The Information Provided?

Content Case Commentary: Pitfalls When Paying Shareholder Dividends – Schonberger v. HMK, Section 160 Of The Income Tax Act

Content Tax Court Of Canada Rejects The CRA’s Attempt To Apply Gross-Negligence Penalties In Statute-Barred Years: Fuhr, Et Al v The King, 2024 TCC 43

Content What To Do When CRA Refuses Taxpayer Relief – A Canadian Tax Lawyer’s Case Commentary On Maverick v HMK, 2023 FC 1728

Content Case Commentary Cassidy v Canada: Using ‘Extraordinary Circumstances,’ CRA’s Delays, Inability To Pay, Or Financial Hardship When Seeking Taxpayer Relief

Content A Canadian Tax Lawyer’s Guide To Canada Emergency Wage Subsidy Claims Audits And Appeals

Content Case Commentary: Csak v The King 2024 TCC – Transfers Of Property While Owing Taxes To The CRA (Tax Court Finds Both 1988 And 1989 Reassessments Of Maria Csak Statue-Barred)

Content Taxpayer Sidesteps Gross-Negligence Penalties And $90,000 In Taxable Income Because Tax Year Was Statute-Barred: Abbass v The King, 2023 TCC 169

Content Do I Have To Submit To An Oral Interview During A Tax Audit? Canadian Tax Lawyer Explains CRA’s Policy

Content Case Commentary: Director Held Personally Liable For Unremitted And Uncollected GST/HST, 'Due Diligence’ Defence Judged Insufficient – Hall v The King (2023)

Content Made A Mistake On Your Tax Return? Here’s How To Change Your Canadian Tax Return Through The Tax Objections Process

Content A Canadian Tax Lawyer Explains Why The ATIP Process Is Critical To Preparing For Tax Disputes With CRA

Content Tax Fraud And Tax Evasion In The Same Case: A Rotfleisch & Samulovitch Analysis Of Regina V Reynolds – Violations Of The Income Tax Act, Excise Tax Act, And Criminal Code Of Canada

Content Benefits Of Paperless Processing For Taxpayers: Lessons For The Canada Revenue Agency (CRA) From Recent Initiatives Of The Internal Revenue Service (IRS)

Content Are CRA Publications Clear And Easy To Understand? Can Canadian Taxpayers Trust Information In CRA Publications?

Content Canadian Taxpayers Must Respond To CRA About Assessments, Reassessments, Confirmations By The Deadline: Oliveira v. The King, 2023 TCC

Content CRA’s Ex Parte Jeopardy Order Application Must Provide Full And Frank Disclosure: Guidance From A Canadian Tax Lawyer

Content Vendor Avoids Liability Selling To Tax-Motivated Arm's-Length Buyer

Content CRA To Introduce New Automatic Tax Filing System As Many Canadians Miss Out On Benefits

Content Canadian Shopify Merchants Beware: The Canada Revenue Agency Is Coming

Content Have Personal Tax Debt That Is More Than 10 Years Old? You May Not Have To Pay CRA, for Tax Debt Over 10 Years Old

Content Can’t Pay Your Taxes? A Primer On When CRA Grants Taxpayer Relief (TPR) On Penalties, Interest

Content When CRA Reassessed A Taxpayer’s Tax Returns Beyond The Normal Reassessment Period: Goldhar v The King, 2023 TCC 30

Content The Israeli Tax Authority, Israel’s Falafel Industry And The Canada Revenue Agency’s Powers To Investigate Unreported Cash Sales: A Canadian Tax Lawyer’s Analysis

Content Federal Court Granted CRA Access To Big Box Store’s Client Lists That May Uncover Tax Fraud And Evasion: Guidance From A Canadian Tax Lawyer On CRA’s Power To Compel Third Parties To Disclose Information

Content Statute-Barred Tax Years And The Canada Revenue Agency’s Powers To Reassess Tax Years: A Canadian Tax Lawyer’s Guide

Content Choptiany Et. Al. v The King, 2022 TCC 112: The Tax Court Of Canada Issues Scathing Rebuke Of CRA’s “Outrageously Misleading And Inappropriate” Litigation Tactics In Tax Dispute Involving Gross-Negligence Penalties

Content 6075420 Canada Inc. v M.N.R.: A Canadian Tax Lawyer’s Guidance On Reassessment Limitation Periods

Content Oddi v CRA: Guidance From A Canadian Tax Lawyer Regarding CRA’s Collection Misconduct

Content MNR v Zhao – Guidance From A Canadian Tax Lawyer On The Canada Revenue Agency’s Collection Action When There Are Reasonable Grounds For Delay

Content Soulliere v The Queen: Director’s Liability For Unpaid Taxes

Content Director Hit With Vicarious Tax Liability: Cliff v The Queen, 2022 FCA 16 – A Canadian Tax Lawyer’s Analysis

Content Federal Court Of Appeal Overturns Tax Court’s Decision And Vacates Gross-Negligence Penalties Because The Canada Revenue Agency’s Evidence Was Exclusively About The Taxpayer’s Spouse: Khanna v The Queen, 2022 FCA 84 – A Canadian Tax Lawyer’s Analysis

Content Zvilna v. Canada: Director’s Liability For Unpaid Taxes: A Canadian Tax Lawyer’s Note Of Caution To Directors

Content Canadian Tax Trap: Dividends From A Corporation With Tax Debts Leads To Derivative Tax Liability: Kufsky V The Queen, 2019 TCC 254 – Canadian Tax Guidance From A Canadian Tax Lawyer

Content A Canadian Tax Lawyer Guide To Third-Party Tax Liabilities Under Section 160 And Section 325

Content Tax Lawyer Analysis: CRA’s Broad Powers To Compel Third Party Information Under Section 231.2 Is Not Without Limits

Content Victoria Moshinsky-Helm v Minister Of National Revenue – Guidance From A Canadian Tax Lawyer On Judicial Review Of A CRA Decision Regarding Former Spouse’s Income Records

Content A Canadian Tax Lawyer’s Guide On Net Worth Assessments

Content Tax Lawyer Guide To Filing Notice Of Objection And Extension Of Time Application

Content A Canadian Tax Lawyer’s Perspective On Income Tax Statute-Barred Periods

Content What Can A Taxpayer Do If A CRA Decision Letter Is Unclear?

Content A Canadian Tax Lawyer’s Perspective On Gross Negligence Penalties And Net Worth Tax Audits

Content Proper Canadian Tax Guidance Saves Taxpayer $100,000 – Canadian Tax Lawyer Case Study

Content Amending Your Tax Returns Beyond Past The Normal Tax Reassessment Period – A Toronto Tax Lawyer Commentary On 1594418 Ontario Inc. v MNR

Content CRA Compelling Disclosure Vs Anonymous Taxpayers Affirmed By Court

Content Tax Court Won’t Uphold Gross-Negligence Penalties: Taxpayer Not Aware Of Accountant Errors

Content CRA’s Represent A Client (RAC) Service: Canadian Tax Lawyer’s Guide

Content The Tax Court Of Canada Sheds Light On Derivative Tax Liability For Trusts And Trustees Under Section 160 Of The Income Tax Act: Goldman v The Queen, 2021 TCC 13 – A Canadian Tax Lawyer’s Analysis

Content Repeated Failure To File Income Tax Penalty

Content Upward Adjustments For Tax Notices Of Objection

Content Tax Court: No Penalty For Tax Return Filed Without Person's Knowledge

Content Why File Tax Returns: Canadian Tax Lawyer’s Guidance

Content Penalties vs. Taxes

Content CRA Remission Guide

Content Canada Revenue Agency Users Locked Out Of Their My Account

Content Judicial Review Of Remission Order Meleca v AGC

Content Arbitrary Tax Assessments And Derivative Tax Liability

Content Tax Risks From Using Underground Banks

Content Eyeball Networks Inc. Butterfly Reorganization & 160(1)

Content Director’s Liability Limitation Period

Content Access To Information And Privacy Act

Content Deyab v The Queen – Successfully Challenging Gross Negligence Penalties

Content Indirect Tax Audit Methods

Content Tax-Audit Loss Carryovers Exceeding $200,000

Content Tax Remission Order

Content Section 160 Brown v The Queen

Content Yorkwest Plumbing Supply Inc. v The Queen – Valuing Inventory

Content Temporary Labour Agencies

Content Business Tax Audit

Content Tax Audit Attention To Staffing Agencies

Content Repeated Failure To Report Income Tax Penalty

Content Harrison v MNR Collections Limitation Period

Content Search Warrant

Content B.T. Céramiques inc., et al. v. Québec Revenue Agency

Content Tax Instalment Payments

Content When Taxpayer’s CRA Accounts Are Breached in Cyberattacks

Content Third Party Penalties Guindon v R

Content Director’s Liability Soulliere v The Queen

Content Double Derivative Tax Liability Queen v Colitto

Content Bayer - Document Production During A Transfer Pricing Audit

Content National Policy For Saying Sorry To Taxpayers

Content Brown v The Queen – Subsection 160(1)

Content Criminal Tax Investigation Softcom v. AGC

Content CRA Tax Audit U.S. Real Estate Transactions

Content Punitive Damage From The CRA Ludmer

Content Covid-19 Pandemic – Tax Limitation Periods To Be Extended

Content Tax Audits Of COVID-19

Content Duque v. The Queen And Director Liability

Content Ploughman v The Queen-Civil Penalties For Third-Party Tax Advisors

Content Objecting To Amend Your Tax Return

Content Appeals By Large Corporations

Content The Queen v Colitto – Clarity To Directors’ Liability

Content AGC v. Valero Energy Inc CRA Power To Require Information

Content Revera Long Term Care Inc. - Normal Reassessment Period

Content Scott v The Queen - Cancelled Arrears Interest

Content Gurpal Saini Challenging the Net-Worth Method of Assessment

Content Equity, Deadline And When CRA Is At Fault Dutka v. The Queen

Content Section 160 Case Study Analysis

Content Why To File Your Taxes

Content White v. The Queen

Content Deadlines For Notice Of Objections

Content 1074022 B.C. Ltd. v. Li – Misinterpretation Of Section 116

Content Scott v Queen

Content Muir v Queen

Content 6075240 Canada Inc. v MNR And The Normal Reassessment Period

Content CRA’s Civil Audits And The Canadian Charter In The Case Of Freidman

Content Singh v R

Content Colitto

Content The CRA's Response To Federal Court Of Appeal's Decision That A Taxpayer Need Not Answer Questions During A CRA Tax Audit – A Canadian Tax Lawyer's Analysis

Content Waiving The Right Of Objection Or Appeal: Tax Lawyer Case Review – Abdalla v The Queen

Content MNR v Cameco

Content Case Comment – Glatt v Canada

Content Canada (National Revenue) v Atlas Tube Canada

Content Henson Trusts

Content Section 160 Third Party Liability

Content Glazer v. Canada

Content Payroll Failure To Submit

Content Payroll Failure To Withold

Content Income Tax Gross Negligence Penalties

Content Third-Party Advisor Penalties

Content Section 160 & Bare Trusts Article

Content Auditor General’s Report On CRA

Content GST/HST Gross Negligence Penalties

Content Indirect Income Verification

Content Truong v R

Content Do Transfers To Agents Invoke Vicarious Tax Liability Under Section 160? A Canadian Tax Lawyer’s Analysis

Content De Facto Directorship – Directors’ Liability For Tax — Toronto Tax Lawyer Analysis

Content Ceasing To Be A Director – Directors’ Liability For Tax – Toronto Tax Lawyer Analysis

Content Important Income Tax Deadlines For Canadians: Tax Returns, Tax Payments, Objections, And Appeals — A Canadian Tax Lawyer’s Tax Guide

Content Sulochana Shantakumar v. Attorney General Of Canada 2018 FC 677 – Case Comment By A Toronto Tax Lawyer On Taxpayer Relief Application

Content Federal Court Upholds the Canada Revenue Agency’s Audit Powers in the Face of Charter Challenge: Campbell v Attorney General of Canada, 2018 FC 683

Content Taxpayers Succeed in claim of Malicious Prosecution against the CRA: Samaroo v. Canada

Content Taxpayers Succeed in claim of Malicious Prosecution against the CRA: Samaroo v. Canada

Content CRA Super Priority for Source Deduction and GST/HST Tax Assessments

Content Sarmadi v. Canada — Credibility in Tax Law Cases

Content CRA Announces Postal Code Tax Audit Project

Content CRA Income Tax Penalties – Failure to File Tax Returns Electronically Penalties

Content Ministry of National Revenue v Cameco Corporation – Limitations on CRA Tax Audit Powers

Content CRA's approach to Taxpayer Relief for Penalties and Interest Since Bozzer

Content Claiming Expenses Without Supporting Tax Documentation

Content CRA Garnishments: Requirements to Pay Tax

Content BP Canada Energy Company v. Canada (National Revenue) – FCA Decision

Content Central Springs Limited – Limitations on CRA Collections Abilities

Content Canada V. Chriss – Directors Tax Liability Defences

Content Tax Refunds: Corporate Tax Credits from Closed Tax Years - Re-Appropriation of Amounts

Content Application for Tax Remission Order

Content Unfiled Tax Returns and Arbitrary Tax Assessments

Content Challenging Underlying Debt on Derivative Income Tax and GST/HST Assessments

Content CRA Tax Collections Policies Update to IC98-1R6

Content CRA new rules for Interest Relief based on Bozzer Case

Content Improvements coming to income tax Notice of Objection process: CRA review by the Auditor General of Canada

Content Daley v. Canada (Attorney General) – 2016 FC 1154 – Judicial Review of Privacy Commissioner Findings

Content CRA Crackdown on Unreported Income from BC Real Estate

Content CRA Tax Audit of Building Contractor Unreported Income

Content Private Campgrounds Tax Audits

Content Relationship of Tax Audit and Tax Collection

Content The Importance of Access to Information and Privacy Requests in Tax Appeals

Content Protocol Between the Appeals and Audit Branches at CRA

Content CRA Tax Return Statistics for the 2016 Personal Tax-Filing Season

Content Recent Fiscal Arbitrators Gross Negligence Penalty Appeals

Content Net Worth Audit and Assessment

Content Income Tax Audit: Ultimate Practical Tax Lawyer Secrets to Tax Audit Survival

Content ConocoPhillips Canada Resources Corp v MNR – s. 220(2.1) & Notice of Objection – Case Comment

Content CRA Duty to Assess with Due Dispatch

Content Canadian Taxpayer Rights: Toronto Income Tax Lawyer Analysis

Content Canada Revenue Agency and the Private Law Duty of Care to Taxpayers

Content Extension of time to file Notice of Objection

Content Director's Liability

Content Taxpayer Relief (Fairness) Application

Content Tax Appeals - Notices of Objection to Fight Tax Assessments (Income Tax and GST/HST)

Content Access to Information and Privacy (ATIP) for Income Tax Disputes

Content CRA Collections – How to deal with your Tax Debt

Content CRA’s Ability to Collect Taxpayer Debts From Third-Parties

Content CRA Jeopardy or Collection Orders

Content Tax Audit Assistance

Tax Appeals and Litigation

Content Judicial Review Of CRA Decisions: Challenging A CRA Refusal In Federal Court

Content Missed CRA Email Notification After A Reassessment: Can You Still File A CRA Objection?

Content GST/HST Tax Court Success: Persistent Litigation Eliminates Gross-Negligence Penalties And Delivers Significant Tax Savings

Content CRA Net Worth Audit Lawyer Canada: How Taxpage.com Successfully Argued Tax Court Of Canada Appeal, Reducing Client’s CRA Tax Reassessment By $400,000+ And Eliminating Gross Negligence Penalties

Content A Canadian Tax Lawyer’s Guide To The Global Learning And Gifting Initiative Charitable Donation Scheme: Cassidy v. The King, 2026 TCC 97

Content Why Tax Court Won’t Reopen GST Appeals Dropped By Mistake: Canadian Tax Lawyer Explains Yi v The King (2026 TCC 82)

Content Approved: $8.7M CRA Data Breach Settlement – How Affected Canadians Can Claim $80, $200, And Up To $5,000 For Verified Claims

Content When The CRA Backs Out Of A Deal: Yes, You Can Enforce A Tax Settlement—Lessons From Zhang v. The King (2026 TCC 71)

Content When CRA Denies Business Losses: How To Respond, Protect Your Tax Deductions, And Win Your Tax Dispute

Content CRA’s Conduct Slammed For Unnecessarily Prolonging Tax Litigation, Increasing Costs: A Canadian Tax Lawyer Analyzes Canada v. Marine Atlantic

Content How Disobeying CRA Will Result In ‘Contempt Of Court’ Charge In Tax Court, Plus Fines And Other Penalties: Minister Of National Revenue v. 1718743 Ontario Inc. (Sanderson Outdoor) Et Al. (2026 FC 435)

Content Smith v. The King – Missed The Deadline To Object To A CRA Tax Reassessment? What The Tax Court Requires To Grant An Extension Of Time

Content The Court Says Fairness Comes First In CRA Decisions, Godin v. Canada (Attorney General), 2024 FC 1386

Content Rawlings v AGC, 2026 FC 208: Taxpayer Sought Judicial Review Of CRA’s Decision To Refuse Changing His 2004 Tax Return

Content Coram Deo Foundation v MNR (2026 BCSC): When An Interim Injunction Plus Charitable Status Is Revoked And Confront Constitutional Limits On CRA’s Authority

Content Tolley v. The King – When Taxpayer Relief, CPP Limitation Periods, And Procedural Finality Abandon Fairness Without A Remedy

Content How A CRA Tax Audit That Uses Bank Deposit Analysis Affects Tax Reassessments In Canadian Tax Litigation: Comparing Premier Fasteners Inc. v The King And Hickman Motors Ltd. v Canada

Content When You’re In Cryptocurrency Tax Litigation With CRA Trial Strategy (Part V): Evidentiary Burden, Expert Evidence, And Credibility At The Tax Court Of Canada

Content When An Oral CRA Refusal Becomes A Reviewable Administrative Decision: Hillcore Financial Corporation v Attorney General Of Canada

Content CRA Cryptocurrency Tax Litigation Business Income vs Capital Gains (Part IV): Including CRA Tax Audits, And Tax Court Appeals

Content Cryptocurrency Tax Litigation Evidence (Part ii): Evidence, Burden Of Proof, And Managing Risk Of A CRA Tax Audit Or CRA Tax Reassessment

Content How To Handle CRA Notice Of Objection For Cryptocurrency Tax Reassessments (Part iii): Managing CRA Tax Audit Risk And CRA Tax Reassessment Exposure

Content How A Taxpayer Won Judicial Review After CRA Determined He Was Not Eligible For CRB: Case Comment Maheshwari v AGC, 2025 FC 1822

Content CRA Cryptocurrency Tax Litigation (Part i): How To Handle CRA Objections, Tax Court Litigation, And More For Cryptocurrency Tax Disputes In Canada

Content Case Comment: Baxter I.C.I. Corp. vs Attorney General Of Canada – Federal Court Will Not Reweigh Evidence In A Judicial Review Application

Content Want Provincial Tax Relief? You Must File Appeals In The Right Court (Even CRA Gets It Wrong)

Content When Judicial Review (Federal Court) Finds That Interest Imposed By CBSA Must Be Waived: Case Comment On Lufthansa Technik Aktiengesellschaft v. AGC

Content Case Commentary: Rotfleisch v. Attorney General Of Canada – Filing An Objection Does Not Stop The Alleged Tax Owing From Accumulating Interest

Content When CRA Is Allowed To Miss Deadlines, Or Why You Need An Experienced Tax Litigation Lawyer In Tax Court: Golden Mind Investment Ltd. v. The King, 2025 TCC 77

Content Tax Court Reprimands CRA With Gross-Negligence Penalties And Procedural Misconduct: Choptiany Et Al. v. The King (2022 TCC 112)

Content Case Comment: How A Taxpayer’s Reliance On Frivolous Tax Appeals, Statute-Barred Tax Challenges In Court Backfired – Boucher v. Canada, 2004 FCA 46

Content Spennie Holdings Inc. v. AGC: Tax Court Is Exclusive Forum For Tax Reassessment Disputes, Not Judicial Review Process

Content When CRA Won’t Cancel Interest, Penalties (Subsection 220(3.1), Taxpayer Relief), You Can Challenge The Decision Through Judicial Review: Minion v The King (2025 FC 1461)

Content When CRA Denies Penalty Relief In Major Non-Compliance Cases: Offshore Income And Aggressive Tax Shelters (2020–2025)

Content When Canadian Taxpayers Have Severe Emotional Trauma, Documentation From Psychologists, Doctors Is Key To Taxpayer Relief Requests: Bifano V Canada (Attorney General)

Content Couture v Canada (Revenue Agency) – How Not To Conduct A Judicial Review

Content Couture v Canada (Revenue Agency): Canadian Tax Lawyer Explains How Not To Conduct A Judicial Review

Content Case Commentary: Schwarz v. HMK – You Must Appeal Within The Deadline For Tax Reassessments; The Tax Court Cannot Forgive Tax Debt

Content Agreements Must Be In Writing: Hutchings v. The King (2025 TCC 108), A Case Of COVID-19 Rent Subsidies

Content Agreements Must Be In Writing: Lessons From Hutchings v. The King (2025 TCC 108) On COVID-19 Rent Subsidies

Content When The CRA Says, "No”: Exploring Judicial Review For Denied Taxpayer Relief From Penalties, Interest Payments On Tax Debt

Content A Primer On Tax Evasion And How To File Voluntary Disclosure Application – Guidance From A Canadian Tax Lawyer

Content Tax Evasion Penalties: Canadian Tax Evasion Versus U.S. Tax Evasion, A Canadian Tax Lawyer Explains The Differences

Content Tax Court Of Canada Is Not ‘Slap-Dash,’ Nor Tolerates Sloppy Examination For Discovery: Whistler Blackcomb Holdings Inc. v The King, 2025, TCC 13: Expert Canadian Tax Litigation Lawyer

Content Case Commentary: Court-Ordered Immediate Seizure ('Jeopardy Order’) Of Taxpayer Assets When Canada Revenue Agency Suspects Fraud, Tax Evasion – Canada (National Revenue) v. Ne’eman Foundation Canada, 2024 FC 1932

Content Comparing The Canadian Voluntary Disclosures Program To The Moroccan Tax Amnesty Program

Content Case Comment: Uppal Estate v. The King, 2024-816(IT)G Upholds Procedural Fairness For Canadian Taxpayers In Tax Litigation With The CRA, Tax Court

Content Case Commentary: Pyxis v. AGC – Rectification Order Does Not Replace Due Diligence, Poorly Drafted Agreements With Accountants

Content When Can Canadian Taxpayers Apply To Reopen A Trial At The Federal Court Of Appeal (FCA) From The Tax Court Of Canada (TCC)? – Doostyar Et Al. v The King

Content Case Commentary: Watts v The King, 2024 TCC 100 – Enhanced Costs Of Litigation

Content When Can A Taxpayer Seek Relief From Penalties, Interest? A Canadian Tax Lawyer Explains CRA’s Taxpayer Relief Provisions

Content A Canadian Tax Lawyer's View On How The CRA Becomes A Victim Of Its Own Incompetence

Content Case Commentary: Onex Corporation v. Canada, 2024 FC 1247 –Subsections 220(2.1) And 220(3) Of The Income Tax Act Can Grant Relief From Tax Reassessment, Plus Filing Requirements

Content Federal Court Grants Relief To Taxpayer Because CRA’s Processing Delays During Judicial Reviews: A Case Comment On Maloney V. Canada (Attorney General), 2024 FC 1474

Content When Can The Federal Court Quash Abusive CRA Decisions To Assess Taxes: A Canadian Tax Lawyer Examines And Explains New 2024 Case Law

Content Want To Appeal A CRA Tax Decision? Here Are The Process Steps For Tax Court Of Canada

Content Do You Have Tax Debts To CRA? Here Are 4 Situations When Taxpayer Relief May Be Possible

Content What Does Tax Court Decide? What Does Federal Court Decide? Supreme Court Clarifies Jurisdictions Through Recent Cases: Dow Chemical And Iris Technologies

Content When Can Discovery Answers Of A Deceased Canadian Be Used Under Subsections 100(6)-(7) Of The Tax Court Of Canada Rules?

Content Case Commentary: Paquet C. Le Roi – Reversing The Burden Of Proof From The Taxpayer To Canada Revenue Agency (CRA)

Content What Is The Standard Of Review For Discretionary Decisions Of The CRA Appealed To The Federal Courts? A Canadian Tax Lawyer Explains

Content CRA Cancels CERB, CRB Debts Of $246 Million Of Canadian Taxpayers Who Were Ineligible To Receive COVID-19 Benefits

Content What To Do When CRA Refuses Taxpayer Relief – A Canadian Tax Lawyer’s Case Commentary On Maverick v HMK, 2023 FC 1728

Content Case Commentary: CRA Violates Procedural Fairness For CERB/CRB Claims - Cameron v. Canada (Attorney General) – Judicial Review At Federal Court

Content When Is It Worth Challenging The CRA’s Defective Tax-Court Pleadings? Reconciling The Federal Court Of Appeal’s Decisions In Preston And Adboss

Content Taxpayers Must Articulate Reasons For Not Responding To Questions In Motions In Tax Court - Richard v Quigley: Powers Of CRA Series

Content Canadian Taxpayers, Beware: The CRA Gets Away With Defective Pleadings During Tax Litigation

Content Are “Hybrid Sales” Of Private Businesses Still A Viable Tax Planning Tool For Business Owners? A Case Comment On Foix v His Majesty The King, 2023 FCA 38

Content Canadian Taxpayer Involved In A Bad Will Investment Scheme Granted Additional Relief On Accrued Interest From Canada Revenue Agency (CRA): Barrs V The Queen Et Al.

Content Determining Eligibility Of The Canada Recovery Benefit: A Canadian Tax Lawyer Examines And Explains Existing Case Law

Content Standards Of Tax Statutes And Tax Caselaw Must Be Respected In Reply From CRA To Taxpayers, Tax Court Of Canada Rules

Content Canadian Taxpayers Must Respond To CRA About Assessments, Reassessments, Confirmations By The Deadline: Oliveira v. The King, 2023 TCC

Content Tax Settlement In Canadian Tax Litigation: Challenges For Canadian Taxpayers

Content Burden Of Proof For Misrepresentation In Tax Reassessments Is High—And Rests With Canada Revenue Agency (CRA)

Content Fighting With CRA? Pick The Right Forum For Tax Disputes: Federal Court Or Tax Court That Has Jurisdiction

Content Can’t Pay Your Taxes? A Primer On When CRA Grants Taxpayer Relief (TPR) On Penalties, Interest

Content Sweet v Canada: Federal Court Of Canada Certified Privacy Breach Class Action On Canada Revenue Agency; A Case Comment By An Expert Canadian Tax Lawyer

Content Rectification Saves Taxpayers From Adverse Tax Consequences Arising From Drafting Error: Sleep Country Canada Holdings & Sleep Country Canada Inc v AGC, 2022 ONSC 6103 – A Canadian Tax-Litigation Lawyer’s Analysis

Content Another Historical Development In Claiming Negligence Against The CRA: Myers v Canada (Attorney General), 2022 BCCA 160

Content Preston Family Trust II v The Queen: Guidance From A Canadian Tax Lawyer Regarding Assumptions Of Facts In Replies To A Notice Of Appeal

Content Barrs v The Queen: A Canadian Tax Lawyer’s Update On Taxpayer Relief Under S.220(3.1)

Content A Tax Lawyer's Guide On Tax Court General Procedural Rule 58

Content Tax Lawyer Guide To Filing Notice Of Objection And Extension Of Time Application

Content A Canadian Tax Lawyer’s Perspective On Tax Court Of Canada Minutes Of Settlement Vs. Consent To Judgement

Content What Can A Taxpayer Do If A CRA Decision Letter Is Unclear?

Content Tax Litigants May Amend Their Arguments During A Trial – A Toronto Tax Lawyer Analysis Of The Queen v Pomeroy Acquireco Ltd

Content Alberta Court Rejects CRA’s Duty Of Care To Taxpayers

Content Rescission For Taxpayers: Canadian Tax Lawyer’s Guide

Content Canada v BCS Group Business Services Inc. Represent Corporations In Tax Court

Content Tax Court Discretion With Costs – Bank Of Montreal v The Queen

Content Taxpayer Relief For Undue Hardship To The Employer

Content Allstaff Inc. v AGC Taxpayer Relief

Content Principled Settlement For Tax Litigation

Content Barbe v AGC – Judicial Review

Content Rectification Application – Mandel

Content When Taxpayer’s CRA Accounts Are Breached in Cyberattacks

Content Neyedly v. AG Judicial Review Of Tax Cases

Content Charitable Donations & Burden Of Proof - Eisbrenner

Content Judicial Review- Sangha v Canada (A.G.)

Content Punitive Damage From The CRA Ludmer

Content Tax Court New Fast Track Settlement Procedure

Content Covid-19 Pandemic – Tax Limitation Periods To Be Extended

Content Onus Of Proof In Tax Litigation

Content TCC Preliminary Ruling Docket

Content Gordon v Queen

Content Bakorp Management Ltd. v. Her Majesty The Queen: Part I – Choice Of Venue Matters

Content Equitable Rescission

Content Subsection 152(9) Article

Content Gordon et al v The Queen

Content Crean v Canada - Rectification Article

Content Truong v R

Content Multiple Taxpayers Successfully Sue The CRA For Damages In Negligence: Ludmer Et Al C. Attorney General Of Canada

Content Sulochana Shantakumar v. Attorney General Of Canada 2018 FC 677 – Case Comment By A Toronto Tax Lawyer On Taxpayer Relief Application

Content Taxpayer Relief For Canadians Affected By Wildfires — A Canadian Tax Lawyer’s Analysis

Content A Canadian Court Need Not Recognize A Foreign Court’s Rectification Order For It To Bind The Canada Revenue Agency: Canadian Forest Navigation Co. Ltd. v Canada, 2017 FCA 39

Content Taxpayers Succeed in claim of Malicious Prosecution against the CRA: Samaroo v. Canada

Content Canada (Attorney General) v. Fairmont Hotels Inc. – SCC Update on Tax Rectification

Content Anderson v. Benson Trithardt Noren LLP – Update on Tax Rectification

Content Burden of Proof at the Tax Court of Canada

Content Canada Revenue Agency and the Private Law Duty of Care to Taxpayers

Content Tax Court Appeals: Notice of Appeal

Content Filing an Appeal with the Federal Court of Appeal

Content Judicial Review of Discretionary Decisions by CRA

Content Correcting Tax Planning Errors

Content Rulings on CRA General Duty of Care a Positive Development

Content CRA Jeopardy or Collection Orders

Tax Evasion

Content What An Israeli Actor’s Tax Evasion Sentence Reveals About Canada’s Tougher Tax Evasion Laws

Content CRA Is Using ‘Unnamed Persons Requirement’ On Canadian Crypto, NFT Holders To Check For Tax Evasion: The Case Against NBA’s Dapper Labs

Content Withdrawing A Guilty Plea Years Later: What Bernier v The King Teaches Canadian Taxpayers Facing Tax Fraud Charges

Content The Ultimate Guide To Offshore Reporting Requirements Of CRA’s Voluntary Disclosures Program (VDP)

Content Why The Voluntary Disclosures Program (VDP) Is Better Than A CRA Tax Audit

Content The Tax Sham vs. Tax Evasion In Canadian Tax Law: Key Differences And Audit Risks (Video)

Content Quebec Entrepreneur Jailed And Ordered To Pay Over $1 Million For GST/QST Fraud – Canadian Tax Lawyer Analysis

Content What Is The CRA's GST/HST Voluntary Disclosures Program?

Content 2025 CRA Voluntary Disclosures Program Changes: How The New Rules Affect Your Canadian Tax Amnesty Application In 2026

Content CRA Rejected Your Voluntary Disclosure: What Taxpayers Should Do Next

Content The Clear Line Between CRA’s Tax Audit vs. A Criminal Tax Investigation: Why R v Jarvis Is The Most Important Tax Case For Canadian Taxpayers

Content 2018 Changes To The Voluntary Disclosure Program (October 2025 Overhaul): A Canadian Tax Lawyer Analysis

Content CRA Using AI To Spearhead Crypto Tax Audits In 2026: How To Use The Voluntary Disclosures Program (VDP) To Disclose Unreported Crypto Profits

Content Canada Crypto Voluntary Disclosure: How Amicarelli v. The King Shows That Many Crypto Profits May Be Business Income—Not Capital Gains

Content Changes To Quebec’s Voluntary Disclosure Program: Eligibility, Obligations, And Tax Forgiveness For Taxpayers

Content Comparing Greek Tax Evasion Reforms To Canadian Tax Compliance Strategies To Reduce Tax Cheating

Content A Canadian Tax Audit Compared With A Criminal Investigation: Important Differences And Legal Protections For Taxpayers In Gravel v. Agence Du Revenu Du Québec

Content Critical Changes In Revenu Québec's Voluntary Disclosure Program And Comparison To Federal CRA Rules For Canadian Taxpayers

Content When CRA And Revenu Québec Tax Audits Turn Into Criminal Investigations: Insights From Gravel v. Agence Du Revenu Du Québec

Content Tax Evasion, Tax Compliance, And Actual Tax Collection Compared: Italy Is Worse, While Canada Is Improving

Content How Tax Lawyers And Accountants Should Navigate Canada’s New Crypto-Asset Reporting Framework

Content Israel’s 2025 Voluntary Disclosure Procedure: Critical Updates And Clarifications For Canadian Taxpayers With Israeli Ties

Content Now Is The Best Time To Fix Past Tax Mistakes: CRA Modernizes The Voluntary Disclosures Program (VDP) – New Rules Effective October 1, 2025

Content What Canadian Taxpayers Must Know About "Unprompted Applications” And "Prompted Applications” Of CRA’s Voluntary Disclosure Program – Guidance From A Canadian Tax Lawyer

Content When Late Filing Penalties Apply Under Subsection 162(7) Plus Your Track Record Of Respecting CRA Filing Deadlines – Laurie v. The King (2025 TCC 130)

Content Israel's New Voluntary Disclosure Program: What It Means For Canadian Taxpayers With Ties To Israel

Content Canada's August 2025 Draft Legislation: What Crypto Investors Need To Know Now

Content CRA Voluntary Disclosure Program (VDP): A Canadian Tax Lawyer’s Guide To The New Rules Effective October 1, 2025

Content Canada Updates Voluntary Disclosure Program (VDP) For GST/HST: New Rules Take Effect October 1, 2025

Content When CRA Denies Penalty Relief In Major Non-Compliance Cases: Offshore Income And Aggressive Tax Shelters (2020–2025)

Content CRA Overhauls The Voluntary Disclosures Program (VDP) – Changes Take Effect On Oct. 1, 2025: Correct Your Unintentional Filing Errors, Omissions

Content Argentine President Milei Eyes Tax Reform To Flag Hidden U.S. Dollars, With Implications For Canada-Argentina Cross-Border Tax Planning

Content In Both Canada And The U.S.A., Sales Of Non-fungible Tokens (NFTs) Are Taxable And Must Be Reported To CRA, IRS, Respectively, Says Canadian Crypto Tax Lawyer

Content A Canadian Tax Lawyer's Update On Voluntary Disclosure: Créations Guimel Inc. v. Canada (National Revenue), 2025 FC 814 – Reviewing CRA's Duty Of Procedural Fairness In VDP In Applications

Content Using COVID-19 Benefits Fraudulently Will Get You Charged With Tax Evasion By The CRA

Content A Primer On Tax Evasion And How To File Voluntary Disclosure Application – Guidance From A Canadian Tax Lawyer

Content Tax Evasion Penalties: Canadian Tax Evasion Versus U.S. Tax Evasion, A Canadian Tax Lawyer Explains The Differences

Content How CRA Uses 'Nudge Letters' With Online Sellers To Increase Uptake Of Canada's Voluntary Disclosures Program

Content Canada Revenue Agency Tightens Oversight On Cryptocurrency Transactions: What You Need To Know Now

Content How Are Foreign Pension Plans, Income From Foreign Pension Plans Treated By CRA In Canada? A Canadian Tax Lawyer Gives Inside Scoop

Content How To Disclose Unreported Income From OnlyFans To The Canada Revenue Agency (CRA) – Here’s The Skinny From A Canadian Tax Lawyer

Content Theft Of CAD$1.5 Billion Of Ethereum: How CRA Treats Stolen Property Tax-Wise; Plus, Tax Implications For Crypto Exchanges In Canada

Content South Africa Is Ramping Up Its Crypto Tax Reporting Compliance Programs

Content Israel Introduces New Options For The Voluntary Disclosure Application; Canadian Voluntary Disclosure Program Remains Unchanged

Content Case Commentary: How The CRA Abused The Voluntary Disclosure Process For This Canadian Taxpayer; Milgram Foundation v. AGC

Content FINTRAC And CRA Team Up To Combat Money Laundering The Proceeds Of Tax Evasion Using Real Estate

Content Israel’s Anticipated, Pilot Voluntary Disclosures Program Gets A Rocky Start -- And Lessons From Canada’s Voluntary Disclosure Program (VDP)

Content When CRA Reassesses An Accepted Voluntary Disclosure Application: The Tax Case Of Milgram Foundation v Canada (Attorney General), 2024, FC 1405

Content Case Study: Canadian Crypto-Tax Lawyers Save Bitcoin Millionaire From Criminal Prosecution For Tax Evasion

Content Taxpayers Beware: CRA’s New Tools For Catching Tax Evasion, Avoiding Tax Debt, Canadian Tax Lawyer Explains

Content Changes Are Coming To Crypto Asset Reporting Framework (CARF), To Crackdown On Tax Evasion: Federal Budget 2024

Content Canadian Tax Lawyer Analyzes Voluntary Disclosure Programs Around The World – Part I: OECD Report On Voluntary Disclosure Program

Content Canadian Tax Lawyer Analyzes Tax Voluntary Disclosure Programs Around The World – Part II: The Canadian Voluntary Disclosure Program

Content Canadian Tax Lawyer Analyzes Tax Voluntary Disclosure Programs Around The World – Part III: Canada Versus The UK

Content Canadian Tax Lawyer Analyzes Tax Voluntary Disclosure Programs Around The World – Part IV: Canada Versus The U.S.A.

Content Canadian Tax Lawyer Analyzes Tax Voluntary Disclosure Programs Around The World – Part V: Canada Versus The E.U. Countries

Content Yes, Convicted Criminals Have To Pay Tax In Canada On: Theft, Fraud, Sex Crimes, Gun Running, Human Trafficking, Terrorist Financing, Narcotics, Crypto Scams And Other Evil Deeds

Content CRA’s Update On Taxation Of Cryptocurrency, NFTs And Form T1135: Guidance From A Canadian Tax Lawyer

Content Canadian Shopify Sellers: Get Ready For The Arrival Of The Canada Revenue Agency

Content Income From Illegal Activities Still Taxable: CRA Targeting Cryptocurrency Transactions Likely Used For Money Laundering, Theft, Fraud, Drugs, Guns, Human Trafficking, Terrorism

Content The Reach Of The Canada Revenue Agency (CRA) Expands In Identifying, Auditing, And Prosecuting Cryptocurrency Investors And Traders: Crypto Users Beware

Content Crypto Tax Trap For Canadian Emigrants: When You Cease To Be A Canadian Tax Resident, Your Cryptocurrency Portfolio May Be Subject To Departure Tax

Content Israel Approved A Draft Bill To Exempt Foreign Residents From Crypto Taxes While Canada Tightens Its Crypto Tax Regulations

Content Canadian Shopify Merchants Beware: The Canada Revenue Agency Is Coming

Content Binance Bids Canada Bye-Bye! Canadian Tax Implications For Cryptocurrency Investors And Traders

Content Warning For Canadian Businesses: The CRA Is Not Sympathetic To Victims Of GST/HST Tax Fraud; The Onus Is On Canadian Taxpayers To Protect Their Businesses From VAT Fraud

Content Canadian Tax Liability For Unreported NFT-Sourced Income: Israel’s Prosecution Of Holy Rock NFT Creators

Content Canadian Crypto-Tax Updates: CRA’s Crypto-Mining Tax Tips Provide Insufficient Clarity

Content Victim Of Cryptocurrency Scams Marketed As “Investments”? There May Be Income Tax Deductions From CRA – Guidance From A Canadian Crypto-Tax Lawyer

Content How To Deal With A Cryptocurrency Tax Audit: Guidance From A Canadian Tax Lawyer

Content The Israeli Tax Authority, Israel’s Falafel Industry And The Canada Revenue Agency’s Powers To Investigate Unreported Cash Sales: A Canadian Tax Lawyer’s Analysis

Content Malaysian And Canadian Tax Authorities Have Adopted Voluntary Disclosure Systems To Curb Tax Evasion & To Reintegrate Non-compliant Taxpayers Into The Tax System

Content Tax Planning To Reduce The Effects Of The FTX Collapse: Advice From A Canadian Tax Lawyer

Content The Canadian Income Tax And Cryptocurrency Staking: Knowing The Income-Tax Consequences For Canadians In The Validation Of Cryptocurrency Transactions In Proof-Of-Stake Blockchain

Content The Ontario Ministry Of Finance’s Voluntary Disclosures Program – A Canadian Tax Lawyer’s Summary

Content Canadian Cryptocurrency Tax Guidance: Tax Liability For DAO Profits And Token Disposition

Content Tax Trap For Canadian NFT Traders, NFT Artists & NFT Content Creators: You Must Obtain Proper Records If You Want To Claim Input Tax Credits

Content Canadian Tax Implications Of The Ethereum Merge: A Guide From A Canadian Tax Attorney

Content Tax Implications: Ontario Crypto Trading Exchanges Introduce Net Annual Purchase Limit For Retail Investors

Content The Ethereum Merge: A Canadian Tax Lawyer’s Guide

Content Foreign Property Reporting Requirements And Paypal Accounts: A Canadian Tax Lawyer’s Guide

Content T1135s, Beneficial Ownership Of Property, And Chan v The Queen: A Canadian Tax Lawyer’s Case Comment

Content Christen v CRA – Guidance From A Canadian Tax Lawyer On Procedural Fairness Regarding The Voluntary Disclosure Program

Content Keeping Records Of Crypto Currency: A Canadian Tax Lawyer’s Guide

Content Taxation Of NFT Rug-Pulls: A Canadian Tax Lawyer’s Guide

Content Fraud Investigators Identify A Potential $1 Billion Crypto-Based Ponzi Scheme And Target Over 50 Criminal Leads In Canada, The US, The UK, Australia & The Netherlands: Tax Implications For Canadian Taxpayers Who Lose Cryptocurrency Or Non-Fungible Tokens Because Of Fraud

Content Canadian Cryptocurrency Tax Planning: Transferring Cryptocurrency To A Bare Trustee Or Holding Cryptocurrency As A Bare Trustee – Canadian Tax Guidance From A Canadian Tax Lawyer

Content A Canadian Tax Lawyer’s Guide To Departure Tax & Cryptocurrencies

Content Canadian Cryptocurrency Tax Trap: Derivative Tax Liability Under Section 160 For Non-Arm’s-Length Cryptocurrency Transactions – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Cryptocurrency Taxation And Divorce

Content Canadian Cryptocurrency Tax Trap: Poor Record-Keeping Will Leave You At The CRA’s Mercy: Record-Keeping Requirements For Canadian Cryptocurrency Traders & Investors – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Voluntariness Of A Voluntary-Disclosure Application 4053893 Canada Inc – A Canadian Tax Lawyer’s Guide

Content Canadian NFT Artists & The Tax Man: The Canadian Tax Implications Of Creating And Selling Blockchain Non-Fungible Tokens (NFTs) – Canadian Tax Guidance From A Canadian Tax Lawyer

Content A Canadian Tax Lawyer’s Perspective On Income Tax Voluntary Disclosure Relief

Content Canadian Income Tax & Cryptocurrency Staking: What Are The Income-Tax Consequences For Canadians Who Validate Cryptocurrency Transactions In Proof-Of-Stake Blockchain? – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Death, Taxes And Cryptocurrency – A Toronto Tax Lawyer Analysis

Content A Canadian Tax Lawyer’s Guidance On T1135 For Cryptocurrencies

Content Tax Consequences Of Bitcoin Mining

Content Canadian Income-Tax Implications Of Cryptocurrency Airdrops – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Taxation Of Cryptocurrency Stablecoins – Guidance From A Canadian Tax Lawyer

Content New Agreement To Relocate One Million Bitcoin Miners From China To Alberta

Content Canadian Income-Tax Implications Of Cryptocurrency Hard Forks – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Taxation Of Cryptocurrency And Barter Transactions – A Toronto Tax Lawyers Analysis

Content The T1135 Foreign-Reporting Exemption & Canadian Cryptocurrency-Trading Businesses & Canadian NFT-Trading Business: Are Canadian Cryptocurrency And NFT Traders Required To File A T1135 Form?

Content A Canadian Tax Lawyer’s Perspective On Provincial Sales Tax Voluntary Disclosure Programs

Content A Canadian Tax Lawyer’s Guide To Income Tax Act Offences And Punishment

Content The Blockchain-Based Video Game With Real Tax Consequences: The Philippines Isn’t The Only Country That Taxes Axie Infinity Players – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Bored Ape Yacht Club – Non-Fungible Tokens – A Canadian Tax Lawyer Analysis

Content Voluntary Disclosure Applications: Canadian Tax Lawyer’s Guide

Content Biden’s Financial-Reporting Obligations For Cryptocurrency Exchanges

Content Tax Implications Of Cryptocurrency Flash Loans

Content Failure To File Tax Returns: Canadian Tax Lawyer Guidance

Content Canadian Income Tax Implications Of Buying & Selling Blockchain NFTs

Content Taxation Of OnlyFans

Content Prince v MNR

Content Tax Risks From Using Underground Banks

Content Criminal Tax Evasion Sentencing

Content Search Warrants

Content Tax Search Warrants

Content Temporary Labour Agencies

Content Auditing, And Prosecuting Cryptocurrency

Content Tax Audit Attention To Staffing Agencies

Content Taxation And The “Dark Web”

Content Search Warrant

Content B.T. Céramiques inc., et al. v. Québec Revenue Agency

Content R. v. Scholz — Document Forging And Tax Fraud

Content Criminal Tax Investigation Softcom v. AGC

Content Regina v Reynolds – Tax Fraud

Content CRA Tax Audit U.S. Real Estate Transactions

Content Tax Audits Of COVID-19

Content Correcting Your Taxes Errors Or Omissions & The Voluntary Disclosures

Content CRA’s Civil Audits And The Canadian Charter In The Case Of Freidman

Content Recent Tightening Of The Voluntary Disclosure Program In Gauthier: A Canadian Tax Lawyer's Perspective

Content 405 Canada Inc v MNR

Content Common Reporting Standard

Content R v Patry

Content Canadian Pensioners Disclosing Prior Year Foreign Income: Implications For Guaranteed Income Supplement Recipients And Their Spouses Or Common-Law Partners - Tax Guide By Canadian Tax Lawyer

Content Canada Revenue Agency Increases Efforts To Uncover Unreported Cryptocurrency & Offshore Income – A Canadian Tax Lawyer’s Analysis

Content Update On The New Voluntary Disclosures Program: Canada Revenue Agency Demands Tax Returns Upfront Despite Contrary Guideline

Content PayPal CRA Court Order - When Shared Economy Becomes Underground Economy

Content Hughes v. the Queen – French versus English Statutory Interpretation – Repeated Failure to File Penalties – ITA s. 162(2)

Content Treatment of GST/HST Under the Proposed VDP Changes

Content Canadian Tax Treatment of Individual Saving Accounts in the United Kingdom

Content Proposed Changes to the Voluntary Disclosures Program (VDP)

Content Providing VDP Relief - Voluntary Disclosures Program Proposed Changes

Content Proposed Changes to the Voluntary Disclosures Program (VDP) – How to Submit a Voluntary Disclosure

Content Proposed Changes to the Voluntary Disclosures Program (VDP) – Conditions of a Valid Disclosure

Content Report on the Voluntary Disclosures Program (VDP)

Content Voluntary Disclosure for Late Tax Return Filing for Non-Charitable Not-For-Profit Organizations

Content CRA Will Fingerprint Canadians Accused of Tax Evasion

Content OECD List of Uncooperative Tax Havens – International Information Sharing

Content Canadian Tax Treatment of Individual Saving Accounts in the United Kingdom

Content Unreported Income - Tax Haven Leak from Bahamas

Content CRA Investigation of Panama Papers Canadians

Content Voluntary Disclosure if More than 10 years Outstanding

Content Tax Protester, Sentenced to Jail in Tax Prosecution

Content Difference between CRA Tax Audits and Tax Investigations

Content Tax Proterster Jailed – Tax Evasion

Content Tax Evasion as a Business – Results in Jail Sentences

Content Underground Economy Tax Evasion Remains CRA Priority

Content Fiscal Arbitrators Owner Sentenced to Jail for Tax Fraud

Content Deceased Taxpayers and the Voluntary Disclosure Program

Content Panama Papers Tax Haven Leak

Content Voluntary Disclosure CRA Latest Statistics

Content Unreported Offshore Assets

Content Unfiled Tax Returns

Content Unreported Offshore Income

Content Voluntary Disclosure

Content Tax Fraud and Tax Evasion in Canada

Content Overseas Tax Informant Program (OTIP)

Tax Planning and Minimization

Content Donating Appreciated Publicly Traded Securities To Charity

Content Can You Deduct Legal Fees Paid For Another Taxpayer’s CRA Dispute? Kruivitsky v. The King

Content What Does A “Gift” Mean For Canadian Income Tax Purposes?

Content Guide To The Canadian Tax Treatment Of Halal Mortgages: Halal Mortgages Are Shari'ah-Compliant But Taxable In Canada

Content Driver Inc. And The Canada Labour Code: Rights For Drivers, Compliance Risks For Carriers

Content Truck Driver Taxes In Canada: What Employees And Owner-Operators Need To Know

Content When Are Legal Fees Tax Deductible In Canada? A Canadian Tax Lawyer’s Guide

Content CRA Changes To The Disability Tax Credit (DTC) Application Process: What Canadian Taxpayers Need To Know

Content What Are The Capital Cost Allowance (CCA) Continuity Rules In Corporate Reorganizations? Suncor Energy Inc. v. His Majesty The King And CRA Reassessment Risk In Canada

Content How To Legally Deduct Leveraged Rental Losses In Your Real Estate Portfolio And Avoid A CRA Rental Audit

Content How To Set Up Lifetime Benefit Trusts In Canada: Tax-Deferred Planning For Disabled Beneficiaries And Registered Assets

Content Tax Court Rejects Employment Expenses Without Proper Receipts: Lessons From Paetz v. The King

Content Arbitrage Betting And Surebetting In Canada: How The CRA Taxes ‘Guaranteed-Profit’ Sports Wagering Strategies

Content CCUS Investment Tax Credit: A Canadian Tax Lawyer’s Guide To Carbon Capture Incentives

Content Paying Employees In Cryptocurrency In Canada: Tax, Payroll Deductions And Considerations

Content How To Claim The Medical Expense Tax Credit In Canada: Eligible Expenses, Common Mistakes When Filing With The CRA, And Tax Planning Tips

Content FIFA World Cup 2026 And Canadian Tax: What Short-Term Renters, Businesses, And Bettors Need To Know

Content Qureshi v. The King -Pre-Construction Condominium Flipping, Principal Residence Claims, And GST Builder Liability – Tax Court Rejects Taxpayer’s Attempt To Treat $456,000 Profit As Tax-Free

Content CRA Rejects Unreasonable Expenses For Commissioned Employees, Despite Having Filled Out Form T2200

Content Is A Ransom Payment For Kidnapped Executives Tax-Deductible In Canada? A Canadian Crypto Tax Lawyer's Analysis

Content Why Interest On Foreign Tax Arrears Is Not Deductible: Canadian Tax Lawyer Explains Tax Court Decision In Bank Of Montreal v. The King, Paragraph 18(1)(a)

Content When The IRS Charges Rappers With Tax Evasion In The United States: What Celebrities And High-Income Earners Need To Know

Content Learn Why The Tax Court Denied $118,000 In Employment Expense Deductions And The Record-keeping Lessons From Chennenkunnath v. The King

Content France's Crypto Kidnapping Surge Exposes A Deeper Risk: What Canadian Crypto Investors Should Know About Tax Data Exposure And CRA Disclosure

Content Why Detailed Record-Keeping Is Critical To Deducting Business Expenses With CRA: A Canadian Tax Lawyer Analyzes Lessons Of Tax Court Case Bobic v. The King

Content Canada Trustco Mortgage Co. v. Canada: The Supreme Court's Foundational GAAR Decision And Its Three-Step Test

Content How Severance Pay Is Taxed In Canada: Guidance From A Canadian Tax Lawyer

Content Tax Treatment Of Employment Settlements In Canada: What Employees And Employers Need To Know Before Signing A Settlement Agreement

Content Unreasonable Business Expenses In Canada: When The CRA Can Deny Your Tax Deduction Under Section 67 Of The Income Tax Act

Content A Canadian Tax Lawyer’s Guide To The Global Learning And Gifting Initiative Charitable Donation Scheme: Cassidy v. The King, 2026 TCC 97

Content CRA Disability Tax Credit: How Type 1 Diabetics Can Secure Retroactive Refunds

Content Navigating The TOSI Rules: Income Splitting & How To Legally Split Corporate Income With Family

Content Small Business Deduction (SBD) in Canada: Section 125 of Canada’s Income Tax Act

Content The Condo Flipping Trap: Why Tax Court Confirms 100% Of Profits Is Business Income Under Canada’s Real Estate Flipping Tax Rules In Qureshi v. The King

Content Restrictive Covenants In Business Sales Or Share Sales: How To Navigate The Default Rule, Plus Statutory Relief From CRA

Content The Complete Arbitrage Betting Canada Tax Guide: Canadian Tax Implications For Prediction Market And Arbitrage Profits (Updated June 2026)

Content Are Poker Winnings Taxable In Canada? Canadian Tax Lawyer Analysis Of Tax Court And Appellate Decisions On Poker Income

Content CRA Shareholder Loan Rules In Canada: Subsection 15(2), Repayment Deadlines, And CRA Audit Risks

Content Crypto Estate Planning In Canada: CRA Tax Treatment On Death, Wills And Inheritance

Content Selling Corporate Real Estate? Canadian Tax Lawyer Explains How The CRA Decides If Your Profit Is Fully (100%) Taxable In 555 Avenue Inc. v. The King

Content Deducting Cross-Border Feasibility Study Costs: Lessons From ExxonMobil Canada Resources Company v. The King, 2026 TCC 42

Content Milne v The King, 2026 TCC 78 –When A Home-Based Business Is Not A “Qualifying Property” Under The Canada Emergency Rent Subsidy (CERS) Program

Content The Stock Option Buyout Trap: Why A Canadian Tax Lawyer Says Tax Timing Is Everything

Content Canada Child Benefit Eligibility After Separation/Divorce: A Canadian Tax Lawyer Explains Why ‘Protected Person’ Status In Immigration Law Ends, In Mohamed v. The King

Content Short-Term Rental Tax Deductions Denied In Canada: New Income Tax Act Rules Target Non-Compliant Landlords

Content How To Meet The Very High Bar For Establishing And Maintaining Canadian-Controlled Private Corporation (CCPC) Status, Plus Corporate And Tax Implications Of Share Transfer

Content Aggressive Tax Planning Schemes, Specially Those Designed By Third Parties, Will Annoy CRA – Canada v. Microbjo Properties Inc.

Content CRA SR&ED Pre-Claim Approval Process (2026): Improved Strategic Tax Planning For SR&ED Tax Credits In Canada With Tax Credit Certainty, Faster Pro

Content For Personal Income Tax In Canada, There Is A Fixed Sequence: Non-Refundable Credits First, Followed By Refundable Credits

Content Federal Court Of Appeal Strikes Down CCPC Continuance Planning Under GAAR In Canada v. DAC Investment Holdings Inc: Guidance From Canadian Tax Lawyer

Content Donating Wine To Charities For Tax Credits? The CRA May Not Agree On What It’s Worth

Content CRA May Apply 2025 Permanent Establishment OECD Rules To Canada: Remote Work, Authority To Bind, Treaty Interpretation & Interprovincial Tax Risk

Content When A Donation Is Not Really A Gift: The Court’s Rejects On Tax-Driven Charity Arrangements, Gifts Must Be Genuine; Walby v. Canada (2025 FCA 94)

Content The Court Says Fairness Comes First In CRA Decisions, Godin v. Canada (Attorney General), 2024 FC 1386

Content Tax Court Of Canada Clarifies Role Of Parties’ Intentions In Worker Classification

Content How Canadian Crypto Traders And Investors Should Handle Losses On Obsolete Crypto Inventory On Their Taxes

Content The 40-Kilometre Rule Revisited: How De Kruyff v The King Clarifies Moving Expense Tax Deductions In The Age Of Google Maps And Traffic Congestion

Content Martin v The King 2024 TCC 153: Canadian Tax Treatment Of Retirement Compensation Arrangements (RCAs) For Non-Resident Professional Athletes – Cross-Border Tax Planning Insights Under Canada-US Tax Treaty

Content Immediate Expensing For Canadian Manufacturers: Unlocking Key Tax Deductions In The 2025 Federal Budget

Content COVID-19 Benefit Repayments Surpass $10 Billion: Implications For Canadian Taxpayers And Businesses, Plus How To Handle Overpayment Claims Or Ineligibility Claims By CRA

Content Federal Court Of Appeal Reaffirms That Tax Efficiency Alone Does Not Equate To Abuse Under GAAR: Canada v. Quebecor Inc., 2025 FCA 207

Content Better Corporate Dividend Tax Planning For Business Owners From A Canadian Tax Lawyer

Content Adjusted Cost Basis Traps In Corporate Life Insurance Planning: How To Avoid Nasty Capital Dividend Account Surprises

Content Canadian Tax Litigation Insights: How The Jennings-Clyde (Vivatas, Inc.) Decision Protects Canadian Taxpayers’ Rights In Federal Court Of Appeal

Content Canadian Students Studying Abroad Beware: Why "Tuition Paid” Does Not Mean "Anything You Paid This Year” - Ojaide v. The King (2025 TCC 180)

Content Tax Consequences Of A Salary Deferral Arrangement (SDA) In Canada: How It Works, Plus Exceptions

Content Case Comment: HMK v. Quebecor Inc. – Federal Court Of Appeal Sides With Taxpayer, Rejects GAAR Challenge To Using Strategy Of Business Losses

Content How A Taxpayer Won Judicial Review After CRA Determined He Was Not Eligible For CRB: Case Comment Maheshwari v AGC, 2025 FC 1822

Content How To Reduce Double Taxation On An Estate Through The Loss Carryback Strategy: Intelligence From A Canadian Tax Lawyer

Content When Negligent Documentation Triggers A Decade-Late Reassessment, Penalties, And Shareholder Liability: Les Éléments Chauffants Tempora Inc. v. The King (2025 TCC 173)

Content Employee Ownership Trusts In Canada: Legislative Refinements, Tax Incentives, And Strategic Succession Planning For Canadian Private Corporations

Content A Guide To Canadian Corporate Dividend Tax Strategy

Content How To Deduct "Loss Leaders,” Other Outrageous Promotional Expenses On Your Canadian Business Taxes: Lessons From A $3.2 Million Giant Bluefin Tuna And Japan’s "Tuna King”

Content Crypto Tax Trap: Financial Products, Services Offered By US-Based Family Offices And Crypto Asset Management Firms May Prove Unworkable For Taxes Due To CRA For Canadian Cryptocurrency Investors

Content Top 21 Tax Changes For 2025 That Canadian Taxpayers Must Know About, From A Canadian Tax Lawyer

Content Canadian Taxpayers: Here Are The Top 20 Tax Changes For 2025 That You Must Know

Content Business And Capital Property Gifts In Canada: Taxable Benefits, Capital Gains Tax, And Using A 'Deed Of Gift’ To Protect Property Transfers

Content Underused Housing Tax Act: The December 31 Late-Filing Trap For Canadian Property Owners

Content Understanding CRA Form T106 And How It Compares To U.S. Reporting Requirements

Content GAAR And Corporate Restarts: Madison Pacific Properties Inc. v. Canada, 2025 FCA 20

Content How The Canadian Tax Court Sees 'Surplus Stripping’ And GAAR: Insights On Abusive Tax Avoidance From D’Arcy v. The King, 2025 TCC 128

Content Doing Cross-Border Transactions? You’ll Need Form T106 To Report Them To CRA – Guidance From A Canadian Tax Lawyer

Content Employment Expense Deductions Canada: Luxury Clothing & Home Office Costs

Content Canada's August 2025 Draft Legislation: What Crypto Investors Need To Know Now

Content CRA Tax Benefits For Canadian Caregivers: Disability Tax Credit (DTC), Medical Expense Tax Credit (METC), And Canada Caregiver Credit (CCC)

Content Canadian Crypto Tax Lawyer’s Review Of The Terra Collapse And Do Kwon’s Guilty Plea

Content A Canadian Crypto Tax Lawyer Analyzes The Terra USD Collapse And Kwon Do-Hyung’s Guilty Plea To Wire Fraud From Crypto Crash

Content Cross-Border Tax: How Trump’s 'One Big Beautiful Bill’ (OBBB) Will Affect Canadians With American Income, Investments, Business Operations

Content Cross-Border Tax Lawyer On Trump’s 'One Big Beautiful Bill’ (OBBB): Key Impacts For Canadians

Content Agreements Must Be In Writing: Hutchings v. The King (2025 TCC 108), A Case Of COVID-19 Rent Subsidies

Content Agreements Must Be In Writing: Lessons From Hutchings v. The King (2025 TCC 108) On COVID-19 Rent Subsidies

Content Does Your Job Require You To Buy Luxury Goods? And, Can You Deduct Those Luxury Goods On Your Taxes? The Case Of Samotus v The King

Content When Are Food Expenses, Meal Expenses Deductible In Canada? Reasonable Expenses When Travelling Is Required For Work, Says Canadian Tax Lawyer

Content How To Structure & Document Rental Properties So CRA Does Not Disallow Rental Expenses

Content A Canadian Tax Lawyer’s Case Commentary On Magren Holdings Ltd. v Canada, 2024 FCA 202: The Application Of General Anti-Avoidance Rule (GAAR) On Capital Dividends

Content The CRA Issues A New Income Tax Folio On 'Deemed Interest Benefit On Shareholder Loans And Debts’: How Is It Treated For Tax Purposes?

Content Blecha v The King – What Expenses Can Owners Deduct From Rental Properties That Produce No Income?

Content When Can Businesses Deduct Interest Payments? A Primer From A Canadian Tax Lawyer

Content The CRA Issues A New ‘Income Tax Folio’ On How Shareholder Loans And Debts Are Treated

Content Cancelling Canada’s Digital Services Tax Creates Immediate Logistical Problems At CRA; Don’t Expect A Refund Soon If You Have Pre-Paid

Content How The Income Tax Act Treats Settlements And Damage Awards For Wrongful Dismissals

Content Using COVID-19 Benefits Fraudulently Will Get You Charged With Tax Evasion By The CRA

Content A Canadian Tax Lawyer’s Guide to the Canadian Tax Treatment Of Domestic, Foreign Retirement Compensation Arrangements (RCAs) for High-Income Earners: Lessons from Martin v The King

Content Chad v The King – Losses, Expenses Arising From Transactions That Are Not 'Sufficiently Commercial’ May Be Ineligible To Reduce Your Income Tax

Content Total Energy Services Inc. v HMK, 2025 FCA 77 – Loss-trading Transactions To Avoid Paying Tax Disallowed By Tax Court Of Canada (GAAR Rule)

Content Canada Revenue Agency Tightens Oversight On Cryptocurrency Transactions: What You Need To Know Now

Content Case Commentary: Ayre v The King, 2025 TCC 41 – Convoluted Charitable Gifts Made Through Questionable Financing Transactions ('Donative Intent’ Under Section 118.1 Of The Tax Act)

Content What Are The CRA Tax Breaks For Canadian Caregivers? Disability Tax Credit (DTC), Medical Expense Tax Credit (METC), And The Canada Caregiver Credit (CCC)

Content Crypto Tax Trap: Are The Tax Advantages Of A Charitable Remainder Trust Worth It For Canadian Cryptocurrency Investors?

Content Employers’ Guide To Specific Tax, Reporting Obligations For Remote Workers To The CRA: Canadian Tax Lawyer

Content Theft Of CAD$1.5 Billion Of Ethereum: How CRA Treats Stolen Property Tax-Wise; Plus, Tax Implications For Crypto Exchanges In Canada

Content South Africa Is Ramping Up Its Crypto Tax Reporting Compliance Programs

Content A Canadian Tax Lawyer’s Guide To Moving Expenses: Who Can Claim Moving Expenses? How Much Can Be Claimed? And Other Criteria

Content The 'Accelerated Investment Incentive’ Is A Valuable Tax Rule, Acting As A Tax Deduction For Eligible Business Owners

Content Income Tax Deductions From Short-term Rental Income: Disallowed Tax Deduction Changes

Content 2024 Tax Alert: CRA Implements Capital Gains Tax Increase Despite Stalled Legislation – The Unique Tax Challenges For Employee Stock Options & Payroll Tax

Content How The FBI Went Fishing With NexFundAI, A Crypto Currency, And Caught "Pump-And-Dump” Market Maker Schemers

Content How To Dispute Your Tax Assessment Under Toronto’s 2024 Vacant Home Tax; 100,000 Tax Assessments Were Reversed In 2023

Content How To Claim Losses From Cryptocurrency Investment Schemes And Scams On Your Tax Returns – Guidance From A Canadian Tax Lawyer

Content Top 24 Year-End Tax Tips For 2024 From A Canadian Tax Lawyer

Content Property Flippers Beware: New Tax Property Flipping Rules Increase Capital Gains To 66.67% Or Even 100% For Business Income

Content 6 Strategies To Minimize Probate Fees In Your Estate Plan

Content Consequences Of Failure To File Valid Business Limit Allocation Agreement With CRA And Missing Out On The Small Business Deduction

Content Case Commentary: Glencore v. Canada – How Are Commitment Fees And Break Fees In M&A Transactions Taxed? Windfall Or Business Income?

Content What Are Alter Ego Trusts? How Can They Help Your Estate Planning?

Content New Digital Services Tax To Impose 3 Percent Tax On Multinational Digital Firms With $20M In Canadian Revenue; Prepare Now, Says Expert Canadian Tax Lawyer

Content How To Leverage The New Tool Employer Ownership Trust For Business Ownership Planning

Content Case Commentary: When Can Directors, Employees, Independent Contractors Claim The Small Business Deduction? – Astro Consulting Inc. v R.

Content How To Determine The Place Of Employment For A Remote Worker: Here Are CRA’s Rules

Content How To Successfully Leverage Employee Ownership Trusts (EOTs) For Business Succession Planning

Content Tenants Beware: Not Remitting Withholding Tax On Rental Payments To Non-Resident Landlords Can Cost You Thousands: 3792391 Canada Inc. v. The King

Content Employees Beware: Upcoming Legislation Affecting Capital Gains Will Impact Employee Stock Options

Content A Comprehensive Guide To Tax For Canadian Property Owners, Investors In Canadian Property Part III: Tax Obligations For Long-Term And Short-Term Rentals

Content Your Health Spending Account (HSA): Benefits And Tax Consequences For Employers, Employees

Content A Canadian Tax Lawyer's Guide For Canadian Property Owners Part II: Tax Liability When Selling Property

Content Case Study: Canadian Crypto-Tax Lawyers Save Bitcoin Millionaire From Criminal Prosecution For Tax Evasion

Content A Comprehensive Guide To Tax For Canadian Property Owners, Investors In Canadian Property – PART 1 – Canadian Tax Lawyer Explains The General Rules

Content Guide To Canadian Tax Rules On Benefits Arising From Use Of Corporate Assets (Money, Trips, Boats, Cars, Space Trips Etc.), Tax Lawyer Explains

Content CRA Cancels CERB, CRB Debts Of $246 Million Of Canadian Taxpayers Who Were Ineligible To Receive COVID-19 Benefits

Content Federal Court Of Appeal Overturns GAAR Assessment On The Existence Of Alternative Transactions, Leading To No Violation Tax Abuse Or Tax Avoidance Of GAAR: 3295940 Canada Inc. v The King

Content Changes Are Coming To Crypto Asset Reporting Framework (CARF), To Crackdown On Tax Evasion: Federal Budget 2024

Content Case Commentary: Persaud v The King – When Can You Claim Tax Deductions (Including Medical Bills) For Dependants? Tax Residence In Canada Is Key

Content Canadian Tax Lawyer Explains CRA’s Policy Positions For Canada’s New Property Flipping Rules

Content News Release Tax Facts 2024 Canadian Tax Lawyer David Rotfleisch

Content Canadian Tax Lawyer Explains The Basics Of Alter Ego Trusts

Content An Overview Of Canadian Foreign Tax Credits For Foreign Withholding Taxes—and Get Ready For An Audit By CRA

Content A Canadian Tax Lawyer Explains The Residential Property Flipping Rule (Bill C-32)

Content How To Transfer A Retiring Allowance From An Employer To Your RRSP; How A Retiring Allowance Is Taxed

Content Can You Claim Income Tax Deductions For Crypto Losses, Crypto Scams? It Depends, Says CRA

Content Case Commentary Cassidy v Canada: Using ‘Extraordinary Circumstances,’ CRA’s Delays, Inability To Pay, Or Financial Hardship When Seeking Taxpayer Relief

Content A Canadian Tax Lawyer’s Guide To Canada Emergency Wage Subsidy Claims Audits And Appeals

Content Tax Planning For Intergenerational Business Transfers And Alternative Minimum Tax (AMT) After Bill C-59 (Changes To The Income Tax Act)

Content How CRA Taxes Tips, Gratuities: Canadian Tax Lawyer Explains They Are Taxable Income

Content Case Commentary: CRA Violates Procedural Fairness For CERB/CRB Claims - Cameron v. Canada (Attorney General) – Judicial Review At Federal Court

Content New Reporting Rules On Tax Treatment Of Severance Settlements; Update From Canadian Tax Lawyer

Content Can Donations To A Charity Be Claimed As A Business Expense? When Can You Deduct Expenses Under The Canadian Income Tax Act?

Content Canadian Tax Lawyer Decodes The 2023 Fall Economic Statement Part III: International Tax Reform And Digital Services Tax

Content Canada Revenue Agency Claws Back $458 Million In CEWs Wage Subsidies From COVID-19 Pandemic Following Audits

Content Tax Complexities In Dealing With The Death Of A Spouse: ODSP And Child Benefits – O’Brien v. The King

Content A Canadian Tax Lawyer’s Guide To Tax Obligations For Foreign Home Buyers In Canada: Bakhtiari v British Columbia (Minister Of Finance), 2023 BCSC 1260

Content A Toronto Tax Lawyer’s Guide For Toronto Vacant Home Tax (VHT)

Content A Canadian Tax Lawyer's Guide To Medical Tax Expenses Eligible For Tax Credits

Content The Federation Of Law Societies Of Canada Challenged The Income Tax Act Amendments Based On Charter Rights Violation

Content Determining Eligibility Of The Canada Recovery Benefit: A Canadian Tax Lawyer Examines And Explains Existing Case Law

Content SRED Tax Credits (Scientific Research And Experimental Development) Upheld By Tax Court Of Canada Against Canada Revenue Agency, In Canafric Inc. V. The King 2023 TCC

Content Supreme Court Of Canada Applies GAAR (General Anti Avoidance Rule) In Deans Knight Income v. Canada, Dismissing Taxpayer’s Appeal

Content CRA Routinely Disallows Parking Expense Claims, Even For Life-Threatening Illnesses

Content The Court Of Canada Rules That Post-Doctoral Fellows Are Not Employees Of The University In The University Of New Brunswick v. The Minister Of National Revenue

Content 5 Important Tax Deductions For Every Small Business In Canada

Content A Tax Guide To Employee Allowances And Reimbursements For Canadian Businesses: What Are The Differences?

Content Thinking Of Co-Signing A Business Loan? Loan Guarantors Are ‘On The Hook’ For The Business’ Debt, Talk To A Canadian Tax Lawyer First

Content When Are Canadian Expats Exempt From Withholding Tax From Employment Income? Under These Specific Circumstances

Content Everything Canadians Need To Know About Unexercised Employee Stock Options: Income Tax Liabilities, Dispositions, Buyouts And Cancellations

Content Canadian Taxation Of U.S. Not Tax-Deductible: Roth IRAs And 401(K) Accounts

Content Everything You Need To Know About The Underused Housing Tax (2022), On Vacant Or Underused Housing In Canada

Content Gordon Et Al v The King: CRA’s Investigation On SR&ED Tax Credits Cannot Use Its Civil Tax Audit Power To Gather Information For A Criminal Investigation

Content Compensation For Business Owners: How Benefits Are Taxed For Shareholders And Shareholder-Employees

Content New Canada Revenue Agency (CRA) Policy On Taxable Benefits Regarding Gifts, Awards, Social Events, Parking, Etc.: A Tax Alert By An Expert Canadian Tax Lawyer

Content Scholarship, Bursaries And Fellowships Taxation: Guidance From A Canadian Tax Lawyer

Content Richard T Mccullough v His Majesty The King: The Tax Court Of Canada Allows Taxpayer’s Travel Expenses Of Getting To Work Denied By The CRA

Content Tax Planning To Mitigate The Impacts Of The FTX Collapse: A Canadian Tax Lawyer’s Advice

Content The Tax Court Of Canada Orders The Canada Revenue Agency To Release GAAR Committee Reports About Similarly Situated Taxpayers

Content Ontario Interactive Digital Media Tax Credit (OIDMTC) – Guidance From A Canadian Tax Lawyer

Content Can You Claim Business Expenses Without Supporting Documents: Guidance From A Canadian Tax Lawyer

Content Deeds Of Gift And Estate Planning: A Canadian Tax Lawyer’s Guide

Content A Canadian Tax Lawyer’s Updates On The Climate Action Incentive

Content A Canadian Tax Lawyer’s Guide To Deemed Dispositions

Content Tax Pipeline Planning: A Canadian Tax Lawyers Guide

Content Canadian Tax Treatment Of Roth Individual Retirement Arrangement (Roth IRA)

Content The Queen V Paletta – Guidance From A Canadian Tax Lawyer Regarding The Legal Test For Business Income

Content A Toronto Tax Lawyer’s Guide To Basic Personal Amount Tax Credit

Content Process Of Passing Of Accounts – Guidance From A Canadian Tax Lawyer

Content Tax Lawyer Analysis: Taxation Of Rental Income From Principal Residence

Content Wall v Canada, 2021 FCA 132 – Guidance From A Canadian Tax Lawyer On Taxation Of House Flipping

Content A Canadian Tax Lawyer’s Perspective On The 12-Month House Flipping Federal Budget Proposal

Content A Canadian Tax Lawyer’s Guidance On The OECD BEPS Project

Content Canadian Tax Lawyer Analysis: Deducting Business Expenses Without Receipts

Content Virtual Witnessing Of Wills And Powers Of Attorney In Ontario : Canadian Tax Lawyer’s Guidance

Content Taxation Of Gifts In Canada – A Canadian Tax Lawyer Analysis

Content Payment Of Insurance Premiums As Shareholder Benefits – A Canadian Tax Lawyer’s Guide To Boyd B. Harding v The Queen

Content Changes To Ontario Estate Law

Content How To Incorporate A Veterinary Professional Corporation – Guidance From A Canadian Tax Lawyer

Content A Canadian Tax Lawyer’s Guide For Non-Residents Investing In Canadian Real Estate

Content Expanded Canada Worker Lockdown Benefit – A Toronto Tax Lawyer Analysis

Content Tax Guidance To The Canada Emergency Wage Subsidy (CEWS) And The Voluntary Repayment Of CEWS – A Canadian Tax Lawyer Tax Guide

Content A Canadian Tax Lawyer’s Guidance On GST/HST On Shareholder Benefits

Content Gifting Shares Of A Publicly Traded Company

Content Canadian Lawyer Analysis – The Supreme Court Of Canada Holds That Tax Treaty Shopping Does Not Constitute Abuse Within The Meaning Of The General Anti-Avoidance Rule (Canada v. Alta Energy Luxembourg

Content Tax Court Rules That Gift Of Shares Of A Private Corporation To A Foundation Was Ineligible For A Charitable Tax Credit – A Canadian Tax Lawyer’s Guide

Content Targeted COVID-19 Business Support Measures - Tourism And Hospitality Recovery Program (THRP), The Hardest-Hit Business Recovery Program (HBRP) And The Canada Recovery Hiring Program (CRHP)

Content Tax Guidance To The Canada Emergency Wage Subsidy (CEWS) And The Voluntary Repayment Of CEWS

Content Emigrating With Stock Options – Canadian Income Tax – Toronto Tax Lawyer Guide

Content Canada’s Preferential Tax Treatment For United Nations Employees: Tax Deduction For UN Employment Income – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Contesting A Will In Ontario: Canadian Tax Lawyer Guide

Content Importance Of Contracts & Written Agreements In Tax Reporting

Content CEWS & Income Tax Act Section 125.7: Canadian Tax Lawyer’s Guide

Content Tax Clearance Certificates: Canadian Tax Lawyer Guidance

Content US-Canada Employee COVID-19 Guidelines: Toronto Tax Lawyer Guide

Content Canada Recovery Hiring Program (CRHP): Toronto Tax Lawyer’s Guide

Content Legal Fees Deduction To Fight Tax Reassessments

Content Tax Court Of Canada’s Rejection Of Solar Panel Shingles As SRED

Content Intergenerational Transfers Of Businesses After Canada’s Bill C-208

Content Corporate Tax Arrangements Of ViacomCBS & Tax Avoidance Schemes

Content Canadian Income Tax Tests For Factual Non-Arm’s Length

Content Employee Stock Options Tax Treatment: Canadian Tax Lawyer’s Guide

Content Marginal Tax Rates Explained By Toronto Tax Lawyer

Content Qualifying For Small Business Deduction: Canadian Tax Lawyer’s Guide

Content A Canadian Tax Lawyer’s Guidance On Business Names

Content Current Rental Expenses

Content CERB Repayment Relief

Content Tax Risks From Using Underground Banks

Content Retirement Compensation Arrangement

Content Ontario’s COVID-19 Business Support Grants

Content T4A Slips To COVID-19 Recipients

Content Protecting Family Assets From CRA In A Divorce

Content T2200 – Deducting Employment Expenses

Content Specified Investment Business

Content Independent Contractor vs Employee

Content Support Payments

Content Repay The Canada Emergency Response Benefit

Content Graduated Rate Estates

Content CRA Low Prescribed Rate

Content Reimbursement To Home Office Equipment

Content Employee Legal Expenses Deduction

Content Home Buyer’s Plan

Content Updates To The Canada Emergency Rent Subsidy

Content Real Estate Assignment

Content Canadian Controlled Private Corporation

Content Incorporation For Real Estate Agents

Content Deducting Home Office Expenses

Content Deduct Motor Vehicle Expenses Gardner v The Queen

Content CRSB, The CRCB And The CRB

Content Lifetime Capital Gains Exemption And QSBC Shares

Content Gifts Tax Analysis

Content Hansen- Principle Residence & House Flipping

Content Capital Gains Reserves

Content Rogers Enterprises (2015) Inc. v The Queen-GAAR

Content Marginal Tax Rates – A Toronto Tax Lawyer Explanation

Content Tax Planning In Commercial Litigation

Content What Is A Taxable Benefit

Content Canada Emergency Wage Subsidy Expansion

Content Salary Deferral Arrangements

Content Shareholder Benefit Decision - Laliberté v. Canada

Content Income Splitting-Prescribed Rate Loans

Content Canada Child Tax Benefit

Content Tax Obligations Of Canadian Sex Workers

Content Separated Couples Living Under The Same Roof

Content Tax Court New Fast Track Settlement Procedure

Content Witnessing Wills Ontario During Covid-19

Content Spousal And Child Support

Content Incorporating A Legal Practice In Ontario

Content Work Space In The Home Expenses

Content Ploughman v The Queen-Civil Penalties For Third-Party Tax Advisors

Content COVID-19 Relief Measures For Businesses

Content COVID-19 Relief Measures for Individuals

Content Estate Planning & Tax Planning During COVID-19

Content Donation Tax Shelter- Roher v. The Queen

Content CHR Investment Corporation v The Queen – GAAR

Content Buy Low Sell High Donation

Content Clergy Residence Deduction

Content Subsection 69(1)

Content Real Estate Transactions, Adventure Or Concern In The Nature Of Trade

Content Condo Flippers

Content Scientific Research And Experimental Development

Content Birchcliff Energy

Content A Power Of Attorney Might Have Unintended Effect If Not Carefully Drafted – Analysis From A Canadian Tax Lawyer

Content Cap On Stock Option Tax Deductions

Content Roofmart

Content Daniel Laplante v The Queen

Content Supreme Court Of Canada Endorses The Federal Court Of Appeal’s Denial Of GST/HST New Housing Rebate Where A Bare Trustee Takes Title – Application For Leave To Appeal Denied: Cheema v The Queen, 2019 Canlii 10518

Content Elections (III) Transfer Of Property Between Spouses

Content Elections (I) Saving Taxes: Elections Are A Great Tool

Content Elections (II) Gifting Property To Your Spouse Or Common Law Partner

Content EHTA & Employee v Contractor

Content Gambling And Poker

Content Convention Expenses

Content Life Insurance Deductions Article

Content Deductibility Of Sales Expenses

Content Repairs And Maintenance Costs

Content Safe Income On Hand – Paying Tax Free Inter-Corporate Dividends

Content Limited Liability Corporation

Content Executors Compensation

Content Tax Attribution Anti-Avoidance Rules

Content Income-Diversion Rules: Section 56 Of The Income Tax Act

Content Canadian Tax Lawyer’s Perspective On Commencing A Business: Tax Planning And The Benefits Of “Specified Small Business Corporation” Status

Content Personal Services Businesses – A Toronto Tax Lawyer Analysis

Content Taxation Of Marijuana Producers

Content The Tax Attribution Anti-Avoidance Rules: Back-to-Back Loans and Transfers, Guarantees, and Artificial Transactions—A Canadian Tax Lawyer’s Guide

Content The Income-Diversion Rules: Section 56 of the Income Tax Act—A Canadian Tax Lawyer’s Analysis

Content 2018 Federal Budget – New Trust Reporting Requirements – A Toronto Tax Lawyer Analysis

Content CRA Monitors Your Bedroom Common Law Marriage for Tax Purposes

Content 2018 Federal Budget – New Trust Reporting Requirements

Content CRA Monitors Your Bedroom Common Law Marriage for Tax Purposes

Content The Tax Attribution Rules: A Response to Income Splitting

Content The Specialized Tax Attribution Rules: Indirect Payments, Tax on Split Income, Corporate Attribution, and Revocable Trusts

Content Tax Losses from Theft and Embezzlement of Bitcoin & Other Assets

Content Eight Estate Freeze Pitfalls & Tax Tips to Avoid Them

Content Amendments to the Income Tax Act – Split Income (TOSI) Rules

Content Top 2017 Year-End Income-Tax Planning Tips from Canadian Tax Lawyers—Part 1: Reducing Taxable Business Income

Content Top 2017 Year-End Income-Tax Planning Tips from Canadian Tax Lawyers—Part 2: Charitable Donations

Content Top 2017 Year-End Income-Tax Planning Tips from Canadian Tax Lawyers—Part 3: Investments

Content Claiming Expenses Without Supporting Tax Documentation

Content Proposed CRA Changes to the Lifetime Capital Gains Exemption

Content When Is a Grantor Capable of Giving a Power of Attorney?

Content Tax Avoidance & Tax Planning – General Anti-Avoidance Rule

Content Income Splitting to Reduce Income Tax – Calgary Tax Lawyer Analysis

Content Family Trusts and Income Splitting

Content Year End Individual Income Tax Planning Tips

Content Optimizing Medical Expenses Tax Credit Claim

Content Employee Stock Options Tax Planning

Content Four Proposed Changes to the Principal Residence Exemption

Content Graduated Rate Estates – Testamentary Planning

Content Changes to the Eligible Capital Property Tax Rules

Content Corporate Attribution To Prevent Income Splitting

Content Disability Tax Credit – Personal Tax Credits

Content Loss Claim from Blogging: Berger v The Queen, 2015 TCC 153

Content Manufacturing and Processing Tax Credits: 13% Tax Saving

Content RRSP Meltdown

Content Private Pension Plans For Professionals

Content Family Trusts For Small Business Tax Planning

Content Tax Return Filings on Death

Content Employee Deduction of Travel Expenses for Commuting

Content Employee Stock Options Tax Planning – Vancouver Tax Lawyer Commentary

Content Child Support Tax Deductions Rules

Content Child Support Deductions and Tax Credits

Content Tax Planning for Deduction of Guarantee Payments

Content Tax Deductions for Spousal Support

Content Need for Business Records

Content Loss From Blogging

Content Business Start-up

Content Canadian Income Tax – Taxation of Termination Fees

Content Deductibility Of Farming Losses

Content Employee vs. Independent Contractor

Content Shareholder Loans

Content Travel Expenses For Medical Treatment

Content Non-Taxable Windfall

Content Kiddie Tax

Content Testamentary Trusts And Income Spliting: A Historical Note

Content Superficial Loss Rules

Content Lifetime Capital Gains Exemption

Content Employee Stock Options

Content Tax Shelters

Content No Gift Taxes in Canada

Content Income Splitting Techniques

Content Succession Will, Estate and Tax Planning

Content Year End Income Tax Planning

Content Automobile Expense Deduction for Canadian Income Tax Purposes

Content Housing Loans

Reorganizations

Content How Canadian Residents Must Report Foreign 'Spin-Off’ Shares Under Section 86.1 Of The Income Tax Act

Content What Are Foreign Spin-Off Shares? How To Report Spin-Off Shares Under Section 86.1 Of Canada’s Income Tax Act

Content A Canadian Tax Lawyer’s Guide To S.51 Rollovers: What And How Shareholders Can Convert Equity Into New Shares Without Capital Gains

Content A Canadian Tax Lawyer’s Guide To Section 85 Late Filed Election

Content A Canadian Tax Lawyer’s Perspective On Business Numbers Upon Amalgamation And Merger

Content A Canadian Tax Lawyer’s Perspective On Dale Et Al. v The Queen -Timing On Issue Of Shares In Section 85 Rollover

Content Intergenerational Transfers Of Businesses After Canada’s Bill C-208

Content Eyeball Networks Inc. Butterfly Reorganization & 160(1)

Content Winding-Up A Corporation

Content Section 85 Rollovers

Content Corporate Amalgamation Under Income Tax Act Section 87

Content Section 84.1 Tax Trap

Content A Caution To Canadian Tax Planners: A Butterfly Reorganization Might Trigger Derivative Tax Liability Under Section 160 Of The Income Tax Act: Eyeball Networks Inc. v The Queen (2019 TCC 150) – A Canadian Tax Lawyer’s Analysis

Content Subsection 55

Content Taxation & Contributing Property To A Partnership

Content 85.1(1) Share For Share Exchange – A Toronto Tax Lawyer Analysis

Content Canadian Income Tax Reorganizations – Contributing Property to a Partnership — Toronto Tax Lawyer Analysis

Content S.86 Share For Share Exchange

Content Butterfly Reorganizations

Tax Deferred Savings Plans

Content Why The Federal Court Of Appeal Upheld 100% Tax On TFSA Advantages: Canadian Tax Lawyer Analyzes Hunt v. Canada, 2026 FCA 88

Content How To Maximize Your Tax-Free Savings Account (TFSA): 7 Strategies To Implement Before Year-End 2025

Content Everything Canadian Families Need To Know About The Two Types Of RESP Withdrawals: Tax-Free vs. Taxable Payments

Content How To Navigate RESP Withdrawals: Essential Tax Tips For Canadian Families

Content Year-End Tax Planning for Tax-Free Savings Accounts: Top TFSA Moves You Should Make Before the End of 2024

Content Fang v. AGC: Fail To Check Your CRA Online Account? Don't Know CRA's Procedures? You Could Owe Significant Tax

Content How To Navigate Tax Incentives For First-Time Home Buyers: Tax Tips From A Canadian Tax Lawyer

Content A Canadian Tax Lawyer’s Guide For First Home Savings Account (FHSA)

Content Overcontributed To Your RRSP? Here’s How To Fix It To Avoid Tax Problems And Penalties

Content When A Tax-Free Savings Account (TFSA) Is A Business & Stripped Of Tax Benefits: A Case Comment On Ahamed v The King, 2023 TCC 17

Content Singh v. Canada: A Canadian Tax Lawyer’s Observations On TFSA Penalties

Content A Canadian Tax Lawyer’s Guide To Registered Disability Savings Plan

Content A Canadian Tax Lawyer’s Analysis On When A Taxpayer Cannot Remove TFSA Over-Contributions

Content TFSA Anti-Avoidance Rules: Prohibited And Non-Qualified Investments – Canadian Income Tax

Content RRSP Double Taxation From Overcontribution – Canadian Income Tax – Toronto Tax Lawyer Guide

Content RRSP Prohibited & Non-Qualified Investments

Content TFSA Anti-Avoidance Rules: TFSA Advantage – Canadian Income Tax – Toronto Tax Lawyer Guide

Content What Happens To Your Registered Retirement Savings Plans (RRSPs) Upon Death? The Designation Of Beneficiaries And Subsection 51(1) Of Ontario’s Succession Law Reform Act – A Canadian Tax Lawyer Tax Guide

Content Proposed First Home Savings Account – Canadian Income Tax – Toronto Tax Lawyer Guide

Content TFSA Tax: Canadian Tax Lawyer Guidance

Content Holding Cryptocurrency, NFTs Or Blockchain Assets In RRSP

Content RRSP And TFSA Over-Contribution Tax: Canadian Tax Lawyer’s Guide

Content RRSP Anti-Avoidance Rules: RRSP Advantage

Content Tax And Penalties On Your TFSA

Content TFSA Penalty Relief And Ifi v. Canada

Content Canadian Departure And RRSPs And TFSAs For Non-Residents

Content RRSP Meltdown Strategy

Content (RRSPs) and Subsection 146(1)

Content Home Buyer’s Plan

Content Transferring A Foreign Pension To Your RRSP

Content Louie v Canada - TFSA Swap Transactions

Content Judicial Review- Sangha v Canada (A.G.)

Content TFSA Non-Residence Contribution Tax Cancellation – A Toronto Tax Lawyer Analysis

Content TFSA Holder Dies

Content Death Of A TFSA Holder

Content Death of a TFSA Holder: You Can’t Take It With You, But Can Your Heirs? A Canadian Tax Lawyer’s Guide

Content Canada Revenue Agency's Aggressive Audit Campaign Against TFSAs Carrying On A Business

Content RRSP Meltdown

Content Tax-Free Savings Accounts – Relief from Assessed Taxes

Content Registered Educational Savings Plans

Content Tax-Free Savings Account (TFSA)

First Home Savings Account (FHSA)

Content How To Navigate Tax Incentives For First-Time Home Buyers: Tax Tips From A Canadian Tax Lawyer

Content A Canadian Tax Lawyer’s Guide For First Home Savings Account (FHSA)

Homebuyers Plan

Content How To Navigate Tax Incentives For First-Time Home Buyers: Tax Tips From A Canadian Tax Lawyer

Content Proposed First Home Savings Account – Canadian Income Tax – Toronto Tax Lawyer Guide

Content Home Buyer’s Plan

Registered Disability Savings Plan

Content A Canadian Tax Lawyer’s Guide To Registered Disability Savings Plan

RESP

Content Everything Canadian Families Need To Know About The Two Types Of RESP Withdrawals: Tax-Free vs. Taxable Payments

Content How To Navigate RESP Withdrawals: Essential Tax Tips For Canadian Families

Content Registered Educational Savings Plans

RRSP

Content Overcontributed To Your RRSP? Here’s How To Fix It To Avoid Tax Problems And Penalties

Content RRSP Double Taxation From Overcontribution – Canadian Income Tax – Toronto Tax Lawyer Guide

Content RRSP Prohibited & Non-Qualified Investments

Content What Happens To Your Registered Retirement Savings Plans (RRSPs) Upon Death? The Designation Of Beneficiaries And Subsection 51(1) Of Ontario’s Succession Law Reform Act – A Canadian Tax Lawyer Tax Guide

Content Holding Cryptocurrency, NFTs Or Blockchain Assets In RRSP

Content RRSP And TFSA Over-Contribution Tax: Canadian Tax Lawyer’s Guide

Content RRSP Anti-Avoidance Rules: RRSP Advantage

Content Canadian Departure And RRSPs And TFSAs For Non-Residents

Content RRSP Meltdown Strategy

Content (RRSPs) and Subsection 146(1)

Content Home Buyer’s Plan

Content Transferring A Foreign Pension To Your RRSP

Content RRSP Meltdown

TFSA

Content Why The Federal Court Of Appeal Upheld 100% Tax On TFSA Advantages: Canadian Tax Lawyer Analyzes Hunt v. Canada, 2026 FCA 88

Content How To Maximize Your Tax-Free Savings Account (TFSA): 7 Strategies To Implement Before Year-End 2025

Content Year-End Tax Planning for Tax-Free Savings Accounts: Top TFSA Moves You Should Make Before the End of 2024

Content Fang v. AGC: Fail To Check Your CRA Online Account? Don't Know CRA's Procedures? You Could Owe Significant Tax

Content When A Tax-Free Savings Account (TFSA) Is A Business & Stripped Of Tax Benefits: A Case Comment On Ahamed v The King, 2023 TCC 17

Content Singh v. Canada: A Canadian Tax Lawyer’s Observations On TFSA Penalties

Content A Canadian Tax Lawyer’s Analysis On When A Taxpayer Cannot Remove TFSA Over-Contributions

Content TFSA Anti-Avoidance Rules: Prohibited And Non-Qualified Investments – Canadian Income Tax

Content TFSA Anti-Avoidance Rules: TFSA Advantage – Canadian Income Tax – Toronto Tax Lawyer Guide

Content TFSA Tax: Canadian Tax Lawyer Guidance

Content Tax And Penalties On Your TFSA

Content TFSA Penalty Relief And Ifi v. Canada

Content Canadian Departure And RRSPs And TFSAs For Non-Residents

Content Louie v Canada - TFSA Swap Transactions

Content Judicial Review- Sangha v Canada (A.G.)

Content TFSA Non-Residence Contribution Tax Cancellation – A Toronto Tax Lawyer Analysis

Content TFSA Holder Dies

Content Death Of A TFSA Holder

Content Death of a TFSA Holder: You Can’t Take It With You, But Can Your Heirs? A Canadian Tax Lawyer’s Guide

Content Canada Revenue Agency's Aggressive Audit Campaign Against TFSAs Carrying On A Business

Content Tax-Free Savings Accounts – Relief from Assessed Taxes

Content Tax-Free Savings Account (TFSA)

Residence Issues

Content Beware Of Tax Implications When A Canadian Corporation Emigrates: Departure Tax, Corporate Emigration Tax, And More

Content Hips Don’t Lie—And Neither Do Flight Records: A Canadian Tax Lawyer On What The Shakira Case Teaches High-Net-Worth, Mobile Canadians

Content Living Abroad? A Tax Lawyer Explains What The Shakira Tax Case Teaches Americans About Moving Wealth

Content Emigrating From Canada To Barbados: Can You Recover Canadian Departure Tax By Disposing Of Property As A Barbados Tax Resident?

Content The Methanex Case: Trinidad And Tobago Courts Uphold International Tax Principles, Scrutinize 'Treaty Shopping’ And Lessons For Canadian Multinational Corporations

Content Methanex Case And International 'Treaty Shopping’ In Search Of Better Tax Breaks: Lessons For Canadian Corporations

Content A Canadian Tax Lawyer’s Guide For Digital Nomads Moving To Canada: Understanding Tax Residence And The Sojourner Rule

Content CRA's 'Deemed Disposition’ Explained: It’s A Departure Tax For Individuals Emigrating From Canada To Live Elsewhere

Content A Canadian Tax Lawyer’s Tax Guide For 'Digital Nomads’ Moving To Canada: What You Need To Know About Canada’s Tax System

Content Exemptions And Rebates (Section 20) Of The Non-Resident Speculation Tax (NRST) For Foreign Real Estate Investors – Guidance From A Canadian Tax Lawyer

Content How An Heir Was Taxed 75% By The UK, Spain On His Inheritance (Just Crumbs Left) And How Tax Treaties Prevent Double Taxation

Content How The Mutual Agreement Procedure (MAP) Can Help Businesses And Individuals Resolve Cross-Border Tax Problems, Plus Tips From Canadian Tax Lawyer

Content Where Are The Best Tax Residence Locations For A Crypto Investor?

Content Beware CRA’s Ability To Share Information With Foreign Tax Authorities Using Tax Information-Exchange Provision In Bilateral Tax Treaties And Tax Information Exchange Agreements: A Canadian Tax Lawyer’s Primer

Content How International Athletes Are Taxed In Canada: Toronto Maple Leafs’ Captain John Tavares Embroiled In Tax Litigation With The CRA – Tavares v. The King, 2024-212(IT)G

Content Crypto Tax Trap For Canadian Emigrants: When You Cease To Be A Canadian Tax Resident, Your Cryptocurrency Portfolio May Be Subject To Departure Tax

Content Crypto Tax Trap For Canadian Emigrants: When You Leave And Cease To Be A Canadian Tax Resident, Your Cryptocurrency Portfolio May Be Subject To Departure Tax

Content How To Legitimately Defer The Worst Of Canada’s ‘Departure Tax’ When Becoming A Non-Resident And Moving To Another Country

Content Planning For The Tax Implications Of Emigrating From Canada While Holding Cryptocurrency Assets

Content How To Interpret A Tax Treaty – Guidance From A Canadian Tax Lawyer

Content A Canadian Tax Lawyer’s Guide To Deemed Dispositions

Content A Canadian Tax Lawyer’s Guide For Non-Residents Investing In Canadian Real Estate

Content Canadian Lawyer Analysis – The Supreme Court Of Canada Holds That Tax Treaty Shopping Does Not Constitute Abuse Within The Meaning Of The General Anti-Avoidance Rule (Canada v. Alta Energy Luxembourg

Content Components Of Foreign Accrual Property Income – Canadian Income Tax – Toronto Tax Lawyer Guide

Content US-Canada Employee COVID-19 Guidelines: Toronto Tax Lawyer Guide

Content Real Estate Taxation For Canadian Non-Resident Owners

Content Acquisition Of Real Estate: Taxation For Canadian Non-Resident Owners

Content How Canada Taxes Non-Resident Musicians: Canadian Tax Lawyer Guide

Content Requirements For Part XIII Withholding Tax On Canadian Interest To Non-Residents – A Toronto Tax Lawyer Guide

Content Canadian Departure Tax: Canadian Tax Lawyer Guidance

Content Tax Treaty Residence Determination: Canadian Tax Lawyer Guide

Content Canadian Nonresidents With Canadian Resident Family

Content Residence Determinations: Canadian

Content Canadian Departure And RRSPs And TFSAs For Non-Residents

Content COVID-19 And Tax Residence

Content Canada-US Tax Treaty

Content Airline-Pilot Residence

Content Regulation 105: Withholding Tax

Content Canada-Israel Income Tax Convention & The Making Of Aliyah

Content Tax Filing for International Students

Content Timing Of Residence Change

Content Income Tax for Canadians At Sea

Content Emigration Tax Issues

Content Snowbird Taxation

Content B2B Loans

Content Non Resident Tax Returns

Content Tax Evasion, Money Laundering

Content Tax Residence In Canada

Content Part-Year Residence

Content Determination Of An Individual’s Residence Status For Canadian Tax Purposes

Content Non-Resident Withholding Tax – Interest Income – A Toronto Tax Lawyer Analysis

Content Non-Resident Carrying on Business in Canada Through Agents and Shareholders

Content Section 216 Election – Canadian Non-Resident Real Estate Taxation

Content Carrying on a Business in Canada by a Non-Resident

Content Departure Tax

Capital Gains

Content ‘Deemed Disposition’ Of All Your Assets At Death: Tax Planning For Canadian Business Owners With High-Net-Worth Estates

Content How The Principal Residence Tax Exemption Works In Canada: Eligibility Requirements, Property Flipping Rules, And Common CRA Tax Traps

Content How To Sell Your Family Business To Your Children Using Bill C-59 ‘Intergenerational Business Transfer Tax Rules’ Of The Income Tax Act (ITA)

Content When The CRA Recharacterizes Capital Gains As Business Income: Happy Valley Farms, Stewart v. Canada, And The Legal Framework Governing CRA Tax Audits And Reassessments

Content Stewart v. Canada: Canadian Tax Lawyer Explains Why Supreme Court Of Canada (SCC) Changed ‘Source Of Income Test’ To Include Legitimate Business Losses, Unsuccessful Ventures

Content Restrictive Covenants In Business Sales Or Share Sales: How To Navigate The Default Rule, Plus Statutory Relief From CRA

Content Selling Corporate Real Estate? Canadian Tax Lawyer Explains How The CRA Decides If Your Profit Is Fully (100%) Taxable In 555 Avenue Inc. v. The King

Content How To Meet The Very High Bar For Establishing And Maintaining Canadian-Controlled Private Corporation (CCPC) Status, Plus Corporate And Tax Implications Of Share Transfer

Content How Canadian Corporations Can Make Better Strategic Decisions With Life Insurance Proceeds And Capital Dividend Account Planning

Content How To Master The 24-Month Holding Period Requirement For QSBC Shares And Lifetime Capital Gains Exemption In Canada

Content Employee Ownership Trusts In Canada: Legislative Refinements, Tax Incentives, And Strategic Succession Planning For Canadian Private Corporations

Content How To Unwind 'Deemed Disposition’ For Returning Canadian Tax Residents – Guidance From A Canadian Tax Lawyer

Content CRA's 'Deemed Disposition’ Explained: It’s A Departure Tax For Individuals Emigrating From Canada To Live Elsewhere

Content When Full Business Income Tax, Other Than Capital Gains Tax, Is Payable If Business Activities Are Based On A "Secondary Intention” Tax Law Doctrine In An "Adventure In The Nature Of Trade” – Guidance From A Canadian Tax Lawyer

Content Canada Revenue Agency (CRA’s) Administration Of Proposed Capital Gains Taxation Changes: An Update

Content How To Leverage The New Tool Employer Ownership Trust For Business Ownership Planning

Content How To Successfully Leverage Employee Ownership Trusts (EOTs) For Business Succession Planning

Content A Canadian Tax Lawyer Explains The Increased Capital Gains Tax Inclusion Rate

Content Canadian Tax Lawyer Explains CRA’s Policy Positions For Canada’s New Property Flipping Rules

Content Canadian Tax Implications Of Buying And Selling Collectible Trading Cards – Magic: The Gathering

Content A Canadian Tax Lawyer’s Guide To Deemed Dispositions

Content Tax Lawyer Analysis: Taxation Of Rental Income From Principal Residence

Content Canadian Tax Treatment Of Stock Splits And Consolidations – A Canadian Tax Lawyer’s Perspective

Content Subsection 164(6) Tax Loss Carryback On Death – A Toronto Tax Lawyer Analysis

Content John Wall- Federal Court Of Appeal Clarifies The Applicability Of The Principal Residence Exemption To Home Developers – A Canadian Tax Lawyer’s Guide

Content Electing Out Of Spousal Rollover On Death: Toronto Tax Lawyer Guide

Content Principal Residence Exemption From Taxation Of Cottages

Content Intergenerational Transfers Of Businesses After Canada’s Bill C-208

Content Real Estate Assignment

Content Canadian Controlled Private Corporation

Content Allowable Business Investment Loss

Content Adventure Or Concern In The Nature Of Trade

Content Hansen- Principle Residence & House Flipping

Content Capital Gains Reserves

Content Rogers Enterprises (2015) Inc. v The Queen-GAAR

Content Section 84.1 Tax Trap

Content Condo Flippers

Content A Canadian Tax Lawyer’s Introduction to Business Income vs. Capital Gains

Content Daniel Laplante v The Queen

Content Safe Income On Hand – Paying Tax Free Inter-Corporate Dividends

Content Crystallizing The Lifetime Capital Gains Exemption – A Toronto Tax Lawyer Analysis

Content GST/HST Section 167 Sale Of A Business Election – Toronto Tax Lawyer Analysis

Content Tax Free Capital Dividends – Elections and Penalties

Content Guide T4037 – Capital Gains Taxation– Principal Residence Exemption - Change in Use

Content Qualified Small Business Corporation and Lifetime Capital Gains Exemption

Content Involuntary Dispositions for Canadian Tax Purposes

Content Lifetime Capital Gains Exemption and Going Public

Content Mergers & Acquisitions – Taxation of Classical Earnouts vs. Reverse Earnouts

Content The S.45(2) Election – Changes in Use of Principal Residence

Content Four Proposed Changes to the Principal Residence Exemption

Content Principal Residence Exemption from Canadian Capital Gains Tax

Content An Allowable Business Investment Loss (ABIL)

Content Superficial Loss Rules

Content Lifetime Capital Gains Exemption

Content Tax Treatment of Expropriated Property

Content Capital Gains on Death

Miscellaneous

Content Bare Trust Tax In Canada: Beneficiary Changes, Trustee Changes And Death Dispositions

Content Bare Trusts Tax Consequences: Canadian Tax Lawyer Guidance

Content CRA Is Using ‘Unnamed Persons Requirement’ On Canadian Crypto, NFT Holders To Check For Tax Evasion: The Case Against NBA’s Dapper Labs

Content Holding Or Moving Cryptocurrency In A Corporation: Learn How CRA’s Taxes Passive Income From Digital Assets

Content Canada's Foreign Influence Transparency Registry: The Income Tax And GST/HST Consequences Registering Organizations Are Missing

Content ‘Deemed Disposition’ Of All Your Assets At Death: Tax Planning For Canadian Business Owners With High-Net-Worth Estates

Content Guide To Crypto Airdrop Tax In Canada: Airdrops And Token Rewards & How They Are Taxed In Canada

Content Who Counts As A “Related Person” Under Canadian Tax Law, To Qualify For Deductions, Rebates And More?

Content Cryptocurrency Tax Enforcement Measures In The U.K. And Canada, Compared By A Crypto Tax Lawyer

Content Is It A Business Or A Hobby? What Triggers A CRA Tax Audit: Pursuit Of Profits, Expenses, Declared Losses

Content How To Legally Deduct Leveraged Rental Losses In Your Real Estate Portfolio And Avoid A CRA Rental Audit

Content Gig Economy Workers Beware How You Are Taxed In Canada: CRA Audit Risks, Creator Income, AI Income, And GST/HST Obligations

Content Hiring Freelancers? How A CRA Audit Can Turn Contractors Into Employees, Costing Businesses Thousands In Back Taxes

Content Arbitrage Betting And Surebetting In Canada: How The CRA Taxes ‘Guaranteed-Profit’ Sports Wagering Strategies

Content Accurate Record-Keeping For Tax Is The Responsibility Of Crypto Traders And Investors: Guidance From An Expert Canadian Tax Lawyer

Content The Complete Guide To Crypto-Asset Reporting Framework (CARF) For 2026-27 For Canadian Crypto Traders, Investors, And Accountants—and Enhanced Mandated Data Sharing Of Wallets With CRA

Content What Traders And Investors Need To Know About Cryptocurrency Tax Audits In Canada: CRA’s Tax Treatment, Audit Methods, Net-Worth Assessments, And Canadian Taxpayer Rights

Content Everything You Need To Know About Crypto Tax Planning Through A Canadian-Controlled Private Corporation (CCPC) In 2026: Incorporation vs. Personal Holding, Expense Deductions, And Integrating With Other Income Sources

Content Canadian Tax Treatment Of Prediction Market Gains And Losses: Polymarket, Kalshi, Event Contracts, And Other Predictive Markets

Content Paying Employees In Cryptocurrency In Canada: Tax, Payroll Deductions And Considerations

Content Canada’s Tax Act Is Too Complex: Complaints About CRA Rise 27% Despite Recent Automated Tax Filing, Call Centre Failures, Processing Delays, Poor Communication

Content Canadian Influencer Tax Guide: CRA Audit Risks, GST/HST Rules, Cryptocurrency Income, Foreign Reporting, And Tax Planning Strategies

Content CRA Rejects Unreasonable Expenses For Commissioned Employees, Despite Having Filled Out Form T2200

Content Is A Ransom Payment For Kidnapped Executives Tax-Deductible In Canada? A Canadian Crypto Tax Lawyer's Analysis

Content Stewart v. Canada: Canadian Tax Lawyer Explains Why Supreme Court Of Canada (SCC) Changed ‘Source Of Income Test’ To Include Legitimate Business Losses, Unsuccessful Ventures

Content Section 160 Cryptocurrency Tax In Canada: CRA Rules For Related-Party Crypto Transfers

Content Why Detailed Record-Keeping Is Critical To Deducting Business Expenses With CRA: A Canadian Tax Lawyer Analyzes Lessons Of Tax Court Case Bobic v. The King

Content When Can Your Crypto Losses Become Tax Deductions? A Canadian Tax Lawyer On Capital Losses vs Business Losses

Content A Complete Guide To The Canada Greener Homes Affordability Program (CGHAP): Tax Implications For Homeowners, Landlords, And Renters

Content Is Student Loan Forgiveness Taxable In Canada? No! Tax Court Rejects CRA’s Attempt To Tax Forgiven Student Loans In Tchiakoua v. The King, 2026 TCC 113

Content Are Poker Winnings Now Taxable In Canada? A Canadian Tax-Lawyer Analyses Of 4 Tax Court Of Canada Recent Poker Decisions

Content King Charles Taxation And Canadian Comparisons: Voluntary Compliance, Crown Privilege, And Tax Transparency

Content Vacant Home Tax 2026 Update: Exemptions, Appeals, Deadlines, Audits, And How To Challenge A Vacant Home Tax Assessment

Content A Tax Lawyer’s Guide to the Luxury Tax in Canada

Content CRA Using AI To Spearhead Crypto Tax Audits In 2026: How To Use The Voluntary Disclosures Program (VDP) To Disclose Unreported Crypto Profits

Content Why Tax Lawyers Have A Secret Weapon Against The CRA & Accountants Don’t: Solicitor-Client Privilege And The Limits Of CRA Audit Powers In Minister Of National Revenue v. KPMG Canada LLP

Content Toronto’s Vacant Home Tax: A Complete Guide To Tax Exemptions, Tax Appeals, And Tax Compliance For Toronto Property Owners

Content Curran v The King (2026 TCC 79): The Fatal Consequences (And Hefty Penalties) Of Pseudo-Legal Tax Arguments

Content The OnlyFans Audit: Why A Canadian Tax Lawyer Warns Creators That The CRA Is Watching (For Income Tax Due)

Content 42,000 Hacked Accounts Since 2020: Why A Canadian Tax Lawyer Says The CRA Failed To Protect Taxpayers

Content The Complete Arbitrage Betting Canada Tax Guide: Canadian Tax Implications For Prediction Market And Arbitrage Profits (Updated June 2026)

Content How CRA Treats Cryptocurrency Tax In Divorce And Family Law Settlements In Canada

Content Panama Papers 10th Anniversary: Canadian Tax Implications, CRA Results & Compliance Lessons For Taxpayers

Content Are Poker Winnings Taxable In Canada? Canadian Tax Lawyer Analysis Of Tax Court And Appellate Decisions On Poker Income

Content Taxation Of Shareholders: The Basic Deemed-Dividend Tax Rules

Content Crypto Estate Planning In Canada: CRA Tax Treatment On Death, Wills And Inheritance

Content Deducting Cross-Border Feasibility Study Costs: Lessons From ExxonMobil Canada Resources Company v. The King, 2026 TCC 42

Content When CRA Denies Business Losses: How To Respond, Protect Your Tax Deductions, And Win Your Tax Dispute

Content CRA Denied Your Business Loss After A Tax Audit? What To Do Immediately To Challenge The Reassessment

Content How To Ensure You’re Compliant With The Spot Rate Requirement Under Section 261(1) Of The Income Tax Act

Content Can The CRA Trace Cryptocurrency? How Blockchain Analytics And AI Are Used In Canadian Crypto Tax Audits

Content The Inside Scoop On 5 Aggressive Tactics The CRA Is Using In Cryptocurrency Audits

Content Crypto Tax Lawyer's Guide To DeFi, Yield Farming, & Liquidity In 2026

Content Crypto Tax Reporting: Canada vs. U.S. (2026); CRA Digital Asset Rules Compared To IRS Form 1099-DA Reporting

Content Foreign Exchange Bureau Compliance In Canada: FINTRAC Reporting, AML Obligations, And CRA Tax Rules For Currency Exchange Businesses

Content Canada Crypto Voluntary Disclosure: How Amicarelli v. The King Shows That Many Crypto Profits May Be Business Income—Not Capital Gains

Content International Crypto Fraud Crackdown: How CRA Treats Tax Losses From Crypto Scams In Canada

Content Toronto Crypto Crackdown Intensifies Enforcement And CRA Tax Audit Risk

Content Creating A U.S. Trust: Canadian Tax Risks To Consider Before CRA’s Review

Content Closing The Loophole On Indirect Trust Transfers And The 21-Year Deemed Disposition Rule: New Measure In Budget 2025

Content CRA Trust Reporting Requirements In Canada: T3 Filing Rules, Bare Trust Updates & Tax Audit Risk

Content When Offshore Trusts Escape Section 94: How To Leverage Planning Opportunities Within Canada’s Exempt Foreign Trust Rules

Content Canadian Charity Revocation Guide: CRA Audit Triggers, Revocation Tax, And Appeal Strategy

Content Using AI To Prepare Legal Documents? They Might Not Have Privilege Protection In Canada

Content Vefghi Holding Corp. v. Canada: How To Avoid The “Tax Trap” On Timing Of Flow-Through For Dividend Income And Timing Of Receipts For Trusts

Content Cineplex Inc. v. The King – When Business Exit Costs, Non-Capital Losses, And Income Characterization Collide

Content How GST Exemptions Work In First Nations’ Commerce: Commentary On Canada v. LBL Holdings Limited (2025 FCA 186)

Content How Canadian Crypto Traders And Investors Should Handle Losses On Obsolete Crypto Inventory On Their Taxes

Content Coram Deo Foundation v MNR (2026 BCSC): When An Interim Injunction Plus Charitable Status Is Revoked And Confront Constitutional Limits On CRA’s Authority

Content How To Properly Claim Employment Insurance Repayments And Protect Your Tax Relief: Lessons From Dandees v. The King (2025 TCC 171)

Content 11 Tax Changes To The Income Tax Act (ITA) In 2026 And Beyond That Canadian Taxpayers, Canadian Businesses Need To Know About

Content Case Comment – Porisky Et Al v The King, 2025 FCA 197

Content How Canadian Corporations Can Make Better Strategic Decisions With Life Insurance Proceeds And Capital Dividend Account Planning

Content Amicarelli v The King: How Cryptocurrency Exchange Losses Are Treated For Tax Purposes Under Canadian Cryptocurrency Tax Laws

Content Cryptocurrency Tax Litigation Evidence (Part ii): Evidence, Burden Of Proof, And Managing Risk Of A CRA Tax Audit Or CRA Tax Reassessment

Content Everything You Need To Know About Cryptocurrency Taxation In Canada: Capital Gains On Crypto And Business Income Strategies

Content CRA Cryptocurrency Tax Litigation (Part i): How To Handle CRA Objections, Tax Court Litigation, And More For Cryptocurrency Tax Disputes In Canada

Content Canada's 2025 Federal Budget: Critical Changes To Cryptocurrency Taxation Investors, Traders, And Miners Need To Know

Content When Is An Accountant’s Work Privileged In Canada: Protecting Accountants’ Work In Tax Matters, Including Litigation

Content CRA’s T4A Reporting Penalties Reinstated In Canadian Trucking Industry: Comprehensive Tax Compliance Guide For Tax Professionals, Entrepreneurs, And Businesses

Content Blake v. Ahmed (2025 BCCA 384) – The Court Of Appeal Reaffirms Limits On Taxpayer Claims And Pseudo-Legal Arguments

Content What Businesses Need To Know About Anti-Deferral Rules For Corporate Tax Planning, From The 2025 Canada Budget

Content Overview Of Cryptocurrency Taxation In Canada: How To Deduct Tax Losses For Digital Assets And Cryptocurrency Investments From Amicarelli v The King

Content How Are 'Catastrophe Bond’ (Cat Bond) Losses Taxed In Canada? Guidance From A Canadian Tax Lawyer

Content Canada’s 2025 Federal Budget: What It Means For Businesses, Investors, And Canadian Taxpayers

Content Canada’s 2025 Federal Budget: What Tax Changes Mean For Entrepreneurs And Business Owners

Content Landmark Israeli Transfer Pricing Ruling And Its Implications For Canadian Tax Law And Canadian Cross-Border Businesses

Content CRA Tax Treatment Of Crypto Staking On CSA Platforms: Guidance From Canadian Crypto Tax Lawyers

Content How Life Insurance Is Taxed In Canada: What You Need To Know Before Making Withdrawals, Claiming Benefits

Content Canada 2025 Draft Tax Changes: Key Updates For Individuals, Corporations, And Trusts

Content Canada’s 2025 Draft Tax Legislation Overview

Content Canada's August 2025 Draft Legislation: What Crypto Investors Need To Know Now

Content A Canadian Tax Lawyer Explains Self-Reporting & Penalty Risks Of Canada’s Enhanced Mandatory Tax Disclosure Rules

Content Seven Essential Steps For Estate Administration Across Canada – Guidance From An Experienced Canadian Tax Lawyer

Content The 7 Steps Of Estate Administration In Canada – Guidance From A Canadian Tax Lawyer

Content Self-Report Or Risk Penalties: Canada’s Enhanced Mandatory Tax Disclosure Rules Explained

Content Tax Reporting Rules, Tax Obligations For Regular Trusts And Bare Trusts: What Canadian Taxpayers Need To Know Now

Content Canadian Crypto Tax Lawyer’s Review Of The Terra Collapse And Do Kwon’s Guilty Plea

Content A Canadian Crypto Tax Lawyer Analyzes The Terra USD Collapse And Kwon Do-Hyung’s Guilty Plea To Wire Fraud From Crypto Crash

Content A Canadian Tax Lawyer’s Updated Guide On Non-Resident Trusts In Canada

Content The CRA Issues A New ‘Income Tax Folio’ On How Shareholder Loans And Debts Are Treated

Content Cancelling Canada’s Digital Services Tax Creates Immediate Logistical Problems At CRA; Don’t Expect A Refund Soon If You Have Pre-Paid

Content A Canadian Tax Lawyer’s Guide To Business And Personal Tax Debt Forgiveness From CRA

Content In Both Canada And The U.S.A., Sales Of Non-fungible Tokens (NFTs) Are Taxable And Must Be Reported To CRA, IRS, Respectively, Says Canadian Crypto Tax Lawyer

Content Tax Obligations And Tax Remittances For Employees Versus Contractors, Misclassification Of Employees In Canada’s Trucking Industry

Content A Canadian Tax Lawyer’s Guide To Changes In Tax Obligations For Trust Executors And Trustees That Will Simplify Estate Administration

Content Top 10 Tax Tips For Navigating Your Obligations In Canada’s Platform Economy

Content How Are Group Benefit Plans Taxed For Employers? How Are Group Benefits Taxed For Employees? What Is Taxable? Non-Taxable?

Content Case Analysis: Why A Business Must Demonstrate Actual Business Activities Before Applying For Business Tax Deductions – Lienaux v. The King

Content What's The Limitation On Losses Of Shares Held As Capital Property For Individuals And Corporations? Canadian Tax Lawyer Explains

Content Chad v The King – Losses, Expenses Arising From Transactions That Are Not 'Sufficiently Commercial’ May Be Ineligible To Reduce Your Income Tax

Content Canada Revenue Agency Tightens Oversight On Cryptocurrency Transactions: What You Need To Know Now

Content How To Disclose Unreported Income From OnlyFans To The Canada Revenue Agency (CRA) – Here’s The Skinny From A Canadian Tax Lawyer

Content Crypto Tax Trap: Are The Tax Advantages Of A Charitable Remainder Trust Worth It For Canadian Cryptocurrency Investors?

Content How Are Limited Partnerships Taxed In Canada? Advantages And Drawbacks From A Canadian Tax Lawyer

Content Theft Of CAD$1.5 Billion Of Ethereum: How CRA Treats Stolen Property Tax-Wise; Plus, Tax Implications For Crypto Exchanges In Canada

Content South Africa Is Ramping Up Its Crypto Tax Reporting Compliance Programs

Content Israel Introduces New Options For The Voluntary Disclosure Application; Canadian Voluntary Disclosure Program Remains Unchanged

Content How CRA Views Crypto Staking On CSA-Compliant Platforms Affect Traders, Investors

Content Special Income Tax Rules In Canada Series Part III: Other Situations Exempt From Income Tax – Some Employment-Income, Strike Pay For Union Workers, And Employment Income From An Employer On A Reserve

Content How The FBI Went Fishing With NexFundAI, A Crypto Currency, And Caught "Pump-And-Dump” Market Maker Schemers

Content Special Income Tax Rules In Canada Series: Part II – Non-Taxable Income Of Prescribed International Organizations, NGOs, And Foreign Embassy Employees In Canada

Content How Canada’s New Luxury Tax Act Affects High-Net-Worth Taxpayers

Content How To Claim Losses From Cryptocurrency Investment Schemes And Scams On Your Tax Returns – Guidance From A Canadian Tax Lawyer

Content City Of Detroit Set To Accept Cryptocurrency For Municipal Tax Payments, Starting In 2025

Content A Canadian Tax Lawyer’s Review Of Special Income Tax Rules In Canada Series: Part I: Taxable Income And Tax Relief For Canadian Armed Forces Members And Veterans

Content Tax Court Rejects The CRA’s Attempt To Obtain Documents Protected By Solicitor-Client Privilege: Stack v The King, 2024 TCC 137

Content 'Bare Trusts' Not Required To File T3, Schedule 15 For 2024 Tax Year, Says CRA

Content Israel's Bill To Exempt Foreigners From Crypto Tax: A Canadian Perspective

Content Case Commentary: Fijal v. The King, 2024 TCC 116 – Why Proper Bookkeeping Is The Best Protection For Businesses When They’re Reassessed By The CRA

Content Why Solicitor-Client Privilege Only Applies To Tax Lawyers, Not Accountants

Content How To Use "Well Accepted Accounting Principles” To Your Advantage To Calculate Business Or Property Income For A Taxation Year

Content Canadian Tax Traps For Professional Athletes Entering, Leaving, Or Playing In Canada: Tax-Planning Considerations For Cross-Border Professional Athletes

Content What Are Alter Ego Trusts? How Can They Help Your Estate Planning?

Content New Digital Services Tax To Impose 3 Percent Tax On Multinational Digital Firms With $20M In Canadian Revenue; Prepare Now, Says Expert Canadian Tax Lawyer

Content Case Commentary: When Can Directors, Employees, Independent Contractors Claim The Small Business Deduction? – Astro Consulting Inc. v R.

Content When Can I Carryover A Loss On My Taxes? CRA’s Audit Policy On Loss Claims Exceeding $200,000

Content More Tax Changes Proposed To Capital Gains Inclusion Rate, Global Minimum Tax Act, Trust Reporting Rules, And Other OEDC Compliance By Canadian Department Of Finance

Content Case Study: Canadian Crypto-Tax Lawyers Save Bitcoin Millionaire From Criminal Prosecution For Tax Evasion

Content Everything You Need To Know About Canada’s New Digital Services Tax Act

Content Changes to Canada's Alternative Minimum Tax (AMT) Target High Income Earners

Content Guide To Canadian Tax Rules On Benefits Arising From Use Of Corporate Assets (Money, Trips, Boats, Cars, Space Trips Etc.), Tax Lawyer Explains

Content Canadian Tax Guide For Uber, Lyft, UberEats, DoorDash, Grubhub & Postmates Drivers: Income Tax & GST/HST Obligations For Commercial Ridesharing And Delivery Services

Content Reversionary Truste Rule: What Is It? When Does It Apply? Not Apply? Canadian Tax Lawyer Explains

Content Changes Are Coming To Crypto Asset Reporting Framework (CARF), To Crackdown On Tax Evasion: Federal Budget 2024

Content A Canadian Tax Lawyer Explains The Increased Capital Gains Tax Inclusion Rate

Content How To Claim A Tax Loss & Tax Deductions For Victims Of 'Pig Butchering’ Fake Crypto Investment Scams Tip: Tips From A Canadian Tax Lawyer

Content TAX UPDATE: CRA Suspends 2023 Tax Returns For Bare Trusts: "Bare Trusts Are Exempt From Trust Reporting Requirements For 2023,” Says CRA

Content Canadian Tax Lawyer Explains The Basics Of Alter Ego Trusts

Content How International Athletes Are Taxed In Canada: Toronto Maple Leafs’ Captain John Tavares Embroiled In Tax Litigation With The CRA – Tavares v. The King, 2024-212(IT)G

Content Can You Claim Income Tax Deductions For Crypto Losses, Crypto Scams? It Depends, Says CRA

Content CRA’s Update On Taxation Of Cryptocurrency, NFTs And Form T1135: Guidance From A Canadian Tax Lawyer

Content Tax Planning For Intergenerational Business Transfers And Alternative Minimum Tax (AMT) After Bill C-59 (Changes To The Income Tax Act)

Content Income From Illegal Activities Still Taxable: CRA Targeting Cryptocurrency Transactions Likely Used For Money Laundering, Theft, Fraud, Drugs, Guns, Human Trafficking, Terrorism

Content Guidance From A Canadian Tax Lawyer: Tax Uncertainties Regarding The Transfer Of Cryptocurrency As Part Of Lending Transactions

Content Canadian Tax Lawyer Decodes The 2023 Fall Economic Statement Part III: International Tax Reform And Digital Services Tax

Content Canadian Tax Lawyer Decodes 2023 Fall Economic Statement – Part II: A Challenge To Build A Competitive Economy

Content Canadian Tax Lawyer Decodes The 2023 Fall Economic Statement – Part I: Canadian Housing Action Plan

Content What Small Businesses Need To Know About Canadian Taxes: A Checklist

Content Record Keeping Of Crypto-Asset Exchanges For Canadian Tax Purposes: Responsibilities Of Traders & Investors

Content The Reach Of The Canada Revenue Agency (CRA) Expands In Identifying, Auditing, And Prosecuting Cryptocurrency Investors And Traders: Crypto Users Beware

Content How Canadian Taxpayers Should Handle Gain Or Loss From Disposition Of NFTs: Unfortunately, Most NFTs Are Worthless; A High Percentage Of NFTs Have Almost Zero Capital Value

Content A Canadian Tax Lawyer’s Guide For Registered Charities In Canada: Non-Resident Withholding Tax

Content Crypto Tax Trap For Canadian Emigrants: When You Cease To Be A Canadian Tax Resident, Your Cryptocurrency Portfolio May Be Subject To Departure Tax

Content A Canadian Tax Lawyer’s Guide To The In-Trust-For (ITF) Account

Content Crypto Tax Trap For Canadian Emigrants: When You Leave And Cease To Be A Canadian Tax Resident, Your Cryptocurrency Portfolio May Be Subject To Departure Tax

Content Israel Approved A Draft Bill To Exempt Foreign Residents From Crypto Taxes While Canada Tightens Its Crypto Tax Regulations

Content The Court Of Canada Rules That Post-Doctoral Fellows Are Not Employees Of The University In The University Of New Brunswick v. The Minister Of National Revenue

Content How Cryptocurrency Rebase Tokens Are Taxed In Canada By CRA

Content Altcoin Purchases On Ontario-Based Crypto Exchanges Are Now Subject To An Annual Limit Of $30,000 CAD

Content Considering A Move To Canada? Income Tax For Permanent Residence For Wealthy Immigrants

Content Canadian Shopify Merchants Beware: The Canada Revenue Agency Is Coming

Content Binance Bids Canada Bye-Bye! Canadian Tax Implications For Cryptocurrency Investors And Traders

Content How Social Media Influencers Are Taxed In Canada- Income Earned Via Instagram, YouTube, WhatsApp, TikTok, Pinterest, Reddit, Facebook

Content Tax Lawyer-Client Confidentiality May Fail To Protect End-Product Tax Documents, Says Federal Court Of Appeal: BMO Nesbitt Burns Inc. v Canada, 2023 FCA 43

Content Independent Contractors Like Cab Drivers Can Be Deemed Employees Even If They File Taxes As “Self-Employed”: Beach Place V. Employment Standards Tribunal (2022)

Content Canadian Tax Liability For Unreported NFT-Sourced Income: Israel’s Prosecution Of Holy Rock NFT Creators

Content Planning For The Tax Implications Of Emigrating From Canada While Holding Cryptocurrency Assets

Content Canadian Crypto-Tax Updates: CRA’s Crypto-Mining Tax Tips Provide Insufficient Clarity

Content Federal Government Introduces New Trust Reporting Rules To Take Effect In 2023 Taxation Year – Trustees Need To Be Prepared

Content How To Use ‘Loss Carryovers’ To Reduce Your Taxable Canadian Income

Content Quebec’s Form TP-1097.PV And The Canada Revenue Agency’s Disclosure Policy Concerning Counter Letters: A Canadian Tax Lawyer’s Summary

Content Compensation For Business Owners: How Benefits Are Taxed For Shareholders And Shareholder-Employees

Content Victim Of Cryptocurrency Scams Marketed As “Investments”? There May Be Income Tax Deductions From CRA – Guidance From A Canadian Crypto-Tax Lawyer

Content How To Deal With A Cryptocurrency Tax Audit: Guidance From A Canadian Tax Lawyer

Content New Canada Revenue Agency (CRA) Policy On Taxable Benefits Regarding Gifts, Awards, Social Events, Parking, Etc.: A Tax Alert By An Expert Canadian Tax Lawyer

Content Proposed Amendments To GST/HST Rules For Cryptocurrency Mining: What’s Covered And What’s Not

Content Using Promissory Notes To Distribute Trust Income To Beneficiaries: A Canadian Tax Lawyer’s Analysis

Content Proposed Notifiable Transactions Under Upcoming Mandatory Disclosure Rules In Canada: A Canadian Tax Lawyer’s Explanation

Content Tax Planning To Reduce The Effects Of The FTX Collapse: Advice From A Canadian Tax Lawyer

Content The Canadian Income Tax And Cryptocurrency Staking: Knowing The Income-Tax Consequences For Canadians In The Validation Of Cryptocurrency Transactions In Proof-Of-Stake Blockchain

Content Tax Planning To Mitigate The Impacts Of The FTX Collapse: A Canadian Tax Lawyer’s Advice

Content Canadian Cryptocurrency Tax Guidance: Tax Liability For DAO Profits And Token Disposition

Content Tax Trap For Canadian NFT Traders, NFT Artists & NFT Content Creators: You Must Obtain Proper Records If You Want To Claim Input Tax Credits

Content Canadian Tax Implications Of The Ethereum Merge: A Guide From A Canadian Tax Attorney

Content Tax Implications: Ontario Crypto Trading Exchanges Introduce Net Annual Purchase Limit For Retail Investors

Content The Ethereum Merge: A Canadian Tax Lawyer’s Guide

Content New Proposed Mandatory Tax Planning Reporting Obligations Under The Canadian Income Tax Act: A Canadian Tax Lawyer’s Review

Content A Canadian Tax Lawyer’s Guide To Alcohol Taxes And Duties

Content A Canadian Tax Lawyers Guide To The Taxation Of Poker Winnings: Duhamel C. Canada, [2022] A.C.I. No 49: A Case Comment

Content Keeping Records Of Crypto Currency: A Canadian Tax Lawyer’s Guide

Content Taxation Of NFT Rug-Pulls: A Canadian Tax Lawyer’s Guide

Content Fraud Investigators Identify A Potential $1 Billion Crypto-Based Ponzi Scheme And Target Over 50 Criminal Leads In Canada, The US, The UK, Australia & The Netherlands: Tax Implications For Canadian Taxpayers Who Lose Cryptocurrency Or Non-Fungible Tokens Because Of Fraud

Content Canadian Cryptocurrency Tax Planning: Transferring Cryptocurrency To A Bare Trustee Or Holding Cryptocurrency As A Bare Trustee – Canadian Tax Guidance From A Canadian Tax Lawyer

Content A Canadian Tax Lawyer’s Guide To Departure Tax & Cryptocurrencies

Content Canadian Cryptocurrency Tax Trap: Derivative Tax Liability Under Section 160 For Non-Arm’s-Length Cryptocurrency Transactions – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Cryptocurrency Taxation And Divorce

Content Canadian Cryptocurrency Tax Trap: Poor Record-Keeping Will Leave You At The CRA’s Mercy: Record-Keeping Requirements For Canadian Cryptocurrency Traders & Investors – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Canadian NFT Artists & The Tax Man: The Canadian Tax Implications Of Creating And Selling Blockchain Non-Fungible Tokens (NFTs) – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Canadian Income Tax & Cryptocurrency Staking: What Are The Income-Tax Consequences For Canadians Who Validate Cryptocurrency Transactions In Proof-Of-Stake Blockchain? – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Death, Taxes And Cryptocurrency – A Toronto Tax Lawyer Analysis

Content A Canadian Tax Lawyer’s Guidance On T1135 For Cryptocurrencies

Content Taxation Of Gifts In Canada – A Canadian Tax Lawyer Analysis

Content Payment Of Insurance Premiums As Shareholder Benefits – A Canadian Tax Lawyer’s Guide To Boyd B. Harding v The Queen

Content Subsection 164(6) Tax Loss Carryback On Death – A Toronto Tax Lawyer Analysis

Content Tax Consequences Of Bitcoin Mining

Content Canadian Income-Tax Implications Of Cryptocurrency Airdrops – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Taxation Of Cryptocurrency Stablecoins – Guidance From A Canadian Tax Lawyer

Content New Agreement To Relocate One Million Bitcoin Miners From China To Alberta

Content Canadian Income-Tax Implications Of Cryptocurrency Hard Forks – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Taxation Of Cryptocurrency And Barter Transactions – A Toronto Tax Lawyers Analysis

Content The T1135 Foreign-Reporting Exemption & Canadian Cryptocurrency-Trading Businesses & Canadian NFT-Trading Business: Are Canadian Cryptocurrency And NFT Traders Required To File A T1135 Form?

Content A Canadian Tax Lawyer’s Guide On Bill C-30 Amendment To The Excise Tax Act – GST/HST Implications For Cryptocurrency Transactions

Content Tax Trap For Canadian Partnerships: The CRA Can Reallocate A Taxpayer’s Income From A Partnership If The Agreed-Upon Allocation Doesn’t Reflect Capital Contributions To The Partnership – Aquilini Et Al. v The Queen, 2021 FCA 206 – A Canadian Tax Lawyer’s Analysis

Content Taxation Of Bitcoin ETFs – A Toronto Tax Lawyer Analysis

Content Canadian Lawyer Analysis: Income Tax Consequences For Employee And Employer Receiving Or Paying Wages Or Salaries In Cryptocurrency

Content What Happens To Your Registered Retirement Savings Plans (RRSPs) Upon Death? The Designation Of Beneficiaries And Subsection 51(1) Of Ontario’s Succession Law Reform Act – A Canadian Tax Lawyer Tax Guide

Content Qualifying Disability Trusts – Canadian Income Tax – Toronto Tax Lawyer Guide

Content The Blockchain-Based Video Game With Real Tax Consequences: The Philippines Isn’t The Only Country That Taxes Axie Infinity Players – Canadian Tax Guidance From A Canadian Tax Lawyer

Content A Canadian Tax Lawyer’s Scary Taxes For Halloween

Content Pandora Papers – Canadian Income Tax – Toronto Tax Lawyer Guide

Content Bored Ape Yacht Club – Non-Fungible Tokens – A Canadian Tax Lawyer Analysis

Content Taxation For eBay & Resellers: Canadian Tax Lawyer’s Guide

Content TFSA Tax: Canadian Tax Lawyer Guidance

Content Holding Cryptocurrency, NFTs Or Blockchain Assets In RRSP

Content Electing Out Of Spousal Rollover On Death: Toronto Tax Lawyer Guide

Content Cryptocurrency: Regulations & Tax Implications Of Crypto Assets Seizure

Content Dividend Refund Rules For Private Corporations

Content Binance’s Exit From Ontario Amid Regulatory Action By OSC

Content Canadian Partnership Status For Income Tax: Toronto Tax Lawyer Guide

Content Cryptocurrency Tax: OECD’s 2021 Cryptocurrency Reporting Framework

Content Biden’s Financial-Reporting Obligations For Cryptocurrency Exchanges

Content Tax Implications Of Cryptocurrency Flash Loans

Content Corporate Tax Arrangements Of ViacomCBS & Tax Avoidance Schemes

Content Taxable Benefits: Canadian Tax Lawyer Analysis

Content Income Tax Installment Payments Often Overlooked By Taxpayers

Content Tax Benefits Of Cryptocurrency-Trading Business As A CCPC

Content Canadian Tax Professionals: A Canadian Tax Lawyer’s Guide

Content Canadian Income Tax Implications Of Buying & Selling Blockchain NFTs

Content Fantasy Sports Winnings Tax Implications: Toronto Tax Lawyer Guide

Content Limited Partnership Losses And The At-Risk Amount

Content CRA Tax Audit & Prosecution For Canadian Crypto Users

Content New Trust Tax Reporting Rules: Toronto Tax Lawyer Analysis

Content Coinsquare Settlement

Content T5018 – Statement Of Contract Payments

Content Cryptocurrency Liquidity Mining & Yield Farming: Return Of Capital

Content Cryptocurrency Liquidity Mining

Content Tax Risks From Using Underground Banks

Content Cryptocurrency Fraudulent Investment Schemes ( Liquidity Mining Repayment)

Content Tax & Cryptocurrency- Computing Inventory Costs

Content Partnership Distribution Timing Trap

Content Tax For Digital Goods And Services

Content Independent Contractor vs Employee

Content CRA’s Auditors Are Watching Canada’s Social Media Influencers

Content Tax-Audit Loss Carryovers Exceeding $200,000

Content CRA Wants Coinsquare To Disclose

Content Auditing, And Prosecuting Cryptocurrency

Content Taxation Of Partnerships

Content Gifts Tax Analysis

Content Partnership Specified Members – A Canadian Tax Lawyer’s Guide

Content Third Party Penalties Guindon v R

Content Director’s Liability Soulliere v The Queen

Content Deemed Dividend Rules

Content Bayer - Document Production During A Transfer Pricing Audit

Content Subsection 69(1)

Content A Canadian Tax Lawyer’s Perspective On Losses And Loss Determinations

Content Commentary On CRA's Cryptocurrency Guideline

Content Windfalls In Canada

Content Tax Clearance Certificates

Content Subsection 40(3.1) - Partnership Negative ACB

Content Tax Issues Involving Agents

Content Taxation Of Settlement Amounts - A Canadian Tax Lawyer

Content HST Holding Company Rules

Content Uber Canada Inc. And The Canada Revenue Agency Settle

Content Canada (National Revenue) v Atlas Tube Canada

Content Daniel Laplante v The Queen

Content Crypto Current And GST

Content CRA Audits Cryptocurrency

Content EHTA & Employee v Contractor

Content Quadriga Tax Implications

Content Third-Party Advisor Penalties

Content Executors Compensation

Content Henson Trusts – Effects Of Changes To The Ontario Disability Support Program — A Toronto Tax Lawyer Analysis

Content Canada Revenue Agency Increases Efforts To Uncover Unreported Cryptocurrency & Offshore Income – A Canadian Tax Lawyer’s Analysis

Content Personal Services Businesses – A Toronto Tax Lawyer Analysis

Content Taxation & Contributing Property To A Partnership

Content Crypto Currency Taxation – Income Tax Implications Of Mining — Toronto Tax Lawyer Analysis

Content Solicitor-Client Privilege For Commonly Interested Parties

Content Solicitor-Client Privilege Bars the Canada Revenue Agency From Compelling Legal-Advice Documents When a Taxpayer Discloses to a Party with a Common Interest: IGGillis Holdings Inc. et al v Minister of National Revenue, 2018 FCA 51

Content Canadian Income Tax Reorganizations – Contributing Property to a Partnership — Toronto Tax Lawyer Analysis

Content 2018 Federal Budget – New Trust Reporting Requirements – A Toronto Tax Lawyer Analysis

Content 2018 Federal Budget – New Trust Reporting Requirements

Content Tax Losses from Theft and Embezzlement of Bitcoin & Other Assets

Content Taxation of Buying and Selling Stocks and Cryptocurrency: Capital Gains or Income?

Content CRA Income Tax Filing Requirements – Requirement to File Partnership T5013 Information Return

Content Dividend Gross-Up and Dividend Tax Credits

Content Taxation of Sales of Bitcoin Before Year End

Content Bitcoin & Cryptocurrency Canadian Reporting Requirements and Tax Planning Tips

Content Taxation of Shareholder Loans

Content Usufructs: What Are They & How Are They Taxed in Canada?

Content Canadian Taxation of Crowdfunding

Content Tax Avoidance & Tax Planning – General Anti-Avoidance Rule

Content Mergers & Acquisitions – Taxation of Classical Earnouts vs. Reverse Earnouts

Content Bitcoin & Cryptocurrency Taxation in Canada

Content Bitcoins are not Cash - Tax and Other Issues with Bitcoin payments

Content Purchase & Sale Hybrid Transaction Structure

Content East and West Tax Protesters Sentenced to Jail in Tax Prosecutions

Content Keith David Lawson, Another Tax Protester, Sentenced to Jail in Tax Prosecution

Content Canadian Income Tax Lawyer 2016 Top Canadian & International Income Tax Stories

Content CRA Raids Accountants Grant Thornton – Only Canadian Tax Lawyers have Privilege

Content Municipal Property Tax Relief

Content Fiscal Arbitrators Owner Sentenced to Jail for Tax Fraud

Content Family Trusts For Small Business Tax Planning

Content When Do You Need Canadian Tax Lawyers versus Accountants?

Content CRA Audits Casino Records of Canadian Gamblers

Content Tax Return Filings on Death

Content Taxation on Death

Content Tax Treatment Of Bitcoins

Content Generally Accepted Accounting Principles and the Income Tax Act

Content Tax Lawyer vs Accountant

Content The Nature of the Work Relationship

Content Solicitor-Client Privilege: No Accountant Privilege

Content Application of the General Anti-Avoidance Rule (GAAR)

Content Transfer Pricing

Content Transfer Pricing Documentation

Content Freemen On The Land

Content No Gift Taxes in Canada

Content Advisor Penalties Not Criminal

Information for Accountants

Content Why Tax Lawyers Have A Secret Weapon Against The CRA & Accountants Don’t: Solicitor-Client Privilege And The Limits Of CRA Audit Powers In Minister Of National Revenue v. KPMG Canada LLP

Content 2026 CRA Callback Service For EFilers: Pro Tax Tips And Critical Details For Tax Preparers

Content CRA EFILE Software Block Security Enhancement

Content CRA Introduces Software-Specific Controls For EFILE Accounts, A Safety Feature, Starting In 2026

Content What Is The EFILE Program? Eligibility, Requirements, Obligations, And Revoking Of Registration: A Guide For Accountants & Tax Preparers

Content The Reasonability Requirement For Administrative Suspension Of EFILE Rights: A Canadian Tax Lawyer Case Analysis Of Virgen v Canada (Attorney General) & The Global ‘Buzz’ Behind The Automation Of Tax Filing And Assessment Processes

Content Third-Party Advisor Penalties

Content BP Canada Energy Company v. Canada (National Revenue) – FCA Decision

Content Chartered Professional Accountants Advantages of Incorporation

Content Solicitor-Client Privilege: No Accountant Privilege

Content Advisor Penalties Not Criminal

e-Filing

Content 2026 CRA Callback Service For EFilers: Pro Tax Tips And Critical Details For Tax Preparers

Content CRA EFILE Software Block Security Enhancement

Content CRA Introduces Software-Specific Controls For EFILE Accounts, A Safety Feature, Starting In 2026

Content What Is The EFILE Program? Eligibility, Requirements, Obligations, And Revoking Of Registration: A Guide For Accountants & Tax Preparers

Content The Reasonability Requirement For Administrative Suspension Of EFILE Rights: A Canadian Tax Lawyer Case Analysis Of Virgen v Canada (Attorney General) & The Global ‘Buzz’ Behind The Automation Of Tax Filing And Assessment Processes

Incorporation for Accountants

Content Chartered Professional Accountants Advantages of Incorporation

No Privilege for Accountants

Content Why Tax Lawyers Have A Secret Weapon Against The CRA & Accountants Don’t: Solicitor-Client Privilege And The Limits Of CRA Audit Powers In Minister Of National Revenue v. KPMG Canada LLP

Content Solicitor-Client Privilege: No Accountant Privilege

Third Party Advisor Penalties

Content Third-Party Advisor Penalties

Content Advisor Penalties Not Criminal

Uncertain Tax Positions

Content BP Canada Energy Company v. Canada (National Revenue) – FCA Decision

Cross-Border Issues

Content Robinson v Canada: Federal Court Sets Strict Mutual Agreement Procedure (MAP) Deadline In Reassessment Deals With CRA

Content Tax Court Shuts Down Foreign Continuance Loophole: CRA Can Tax A Canadian-Controlled Private Corporation (CCPC): Lessons From Somerset Limited v The King, 2026 TCC 123

Content Foreign Pension Income Taxation: A Canadian Tax Lawyer Analysis

Content How CRA Taxes U.S. ‘Profits Interests’ – Canadian Tax Lawyer Explains How To Avoid Double Taxation

Content A Canadian Tax Lawyer’s Guide To Canada’s 2026 Proposed Hybrid Mismatch Rules: What Multinational Enterprises And Cross-Border Investors Need To Know

Content Deducting Cross-Border Feasibility Study Costs: Lessons From ExxonMobil Canada Resources Company v. The King, 2026 TCC 42

Content Withholding Tax And Beneficial Ownership: Insights From A Canadian Tax Lawyer On C&W Offshore Ltd. v. HMK, 2026 TCC 40

Content Creating A U.S. Trust: Canadian Tax Risks To Consider Before CRA’s Review

Content How The Canadian Foreign Accrual Property Income (FAPI) Regime Works—and Why It Matters To Foreign Corporations, Foreign Trusts

Content Canada’s Anti-Deferral Regime And The FAPI Rules: When Offshore Trust Structures Trigger More Tax

Content Unpaid Payroll Deductions: Federal Court Of Appeal Affirms Bona Fide Purchaser Defence For Unsecured Creditors

Content Martin v The King 2024 TCC 153: Canadian Tax Treatment Of Retirement Compensation Arrangements (RCAs) For Non-Resident Professional Athletes – Cross-Border Tax Planning Insights Under Canada-US Tax Treaty

Content BC Foreign Buyer Tax vs Ontario Non-Resident Speculation Tax: Comprehensive Guide To Rates, Exemptions, Key Differences, Implications, And Compliance For Canadian Real Estate Investors And Foreign Buyers

Content Canada's August 2025 Draft Legislation: What Crypto Investors Need To Know Now

Content A Canadian Tax Lawyer’s Updated Guide On Non-Resident Trusts In Canada

Content Canadian Tax Consequences Of A Foreign Life Insurance Policy: CRA’s Form T1135 And Reporting Requirements – Canadian Tax Lawyer Explains What You Need To Do

Content What Is CRA’s Regulation 105? An Overview On Withholding Tax On Payments To Non-Residents, Explained By Canadian Tax Lawyer

Content South Africa Is Ramping Up Its Crypto Tax Reporting Compliance Programs

Content Israel Introduces New Options For The Voluntary Disclosure Application; Canadian Voluntary Disclosure Program Remains Unchanged

Content CRA Reaffirms Withholding Taxes For Non-resident Contractors Under Regulation 105 And Its Recent Update: A Canadian Tax Lawyer Explains The Tax Rules

Content Tenants Beware: Not Remitting Withholding Tax On Rental Payments To Non-Resident Landlords Can Cost You Thousands: 3792391 Canada Inc. v. The King

Content How To Navigate IRS Form W-8BEN-E For Canadian Businesses With American Suppliers

Content Canadian Olympic Athletes May Be Taxed In France & How International Athletes Are Taxed In Canada: A Canadian Lawyer Explains Tax Rules

Content Case Study: Canadian Crypto-Tax Lawyers Save Bitcoin Millionaire From Criminal Prosecution For Tax Evasion

Content A Canadian Tax Lawyer’s Guide On ‘Part XIII’ Withholding Tax On Non-Residents Who Receive Property Income From Canadian Residents A Case Study Of 3792391 Canada Inc. v The King

Content Changes Are Coming To Crypto Asset Reporting Framework (CARF), To Crackdown On Tax Evasion: Federal Budget 2024

Content Everything You Need To Know About The Underused Housing Tax (2022), On Vacant Or Underused Housing In Canada

Content Foreign Property Reporting Requirements And Paypal Accounts: A Canadian Tax Lawyer’s Guide

Content T1135s, Beneficial Ownership Of Property, And Chan v The Queen: A Canadian Tax Lawyer’s Case Comment

Content Keeping Records Of Crypto Currency: A Canadian Tax Lawyer’s Guide

Content Taxation Of NFT Rug-Pulls: A Canadian Tax Lawyer’s Guide

Content Fraud Investigators Identify A Potential $1 Billion Crypto-Based Ponzi Scheme And Target Over 50 Criminal Leads In Canada, The US, The UK, Australia & The Netherlands: Tax Implications For Canadian Taxpayers Who Lose Cryptocurrency Or Non-Fungible Tokens Because Of Fraud

Content A Canadian Tax Lawyer’s Analysis On Corporate Tax Residence

Content Canadian Cryptocurrency Tax Planning: Transferring Cryptocurrency To A Bare Trustee Or Holding Cryptocurrency As A Bare Trustee – Canadian Tax Guidance From A Canadian Tax Lawyer

Content A Canadian Tax Lawyer’s Guide To Departure Tax & Cryptocurrencies

Content Canadian Cryptocurrency Tax Trap: Derivative Tax Liability Under Section 160 For Non-Arm’s-Length Cryptocurrency Transactions – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Cryptocurrency Taxation And Divorce

Content Canadian Cryptocurrency Tax Trap: Poor Record-Keeping Will Leave You At The CRA’s Mercy: Record-Keeping Requirements For Canadian Cryptocurrency Traders & Investors – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Canadian NFT Artists & The Tax Man: The Canadian Tax Implications Of Creating And Selling Blockchain Non-Fungible Tokens (NFTs) – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Canadian Income Tax & Cryptocurrency Staking: What Are The Income-Tax Consequences For Canadians Who Validate Cryptocurrency Transactions In Proof-Of-Stake Blockchain? – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Death, Taxes And Cryptocurrency – A Toronto Tax Lawyer Analysis

Content A Canadian Tax Lawyer’s Guidance On T1135 For Cryptocurrencies

Content Tax Consequences Of Bitcoin Mining

Content Canadian Income-Tax Implications Of Cryptocurrency Airdrops – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Taxation Of Cryptocurrency Stablecoins – Guidance From A Canadian Tax Lawyer

Content A Canadian Tax Lawyer’s Guide For Non-Residents Investing In Canadian Real Estate

Content New Agreement To Relocate One Million Bitcoin Miners From China To Alberta

Content Canadian Income-Tax Implications Of Cryptocurrency Hard Forks – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Taxation Of Cryptocurrency And Barter Transactions – A Toronto Tax Lawyers Analysis

Content The T1135 Foreign-Reporting Exemption & Canadian Cryptocurrency-Trading Businesses & Canadian NFT-Trading Business: Are Canadian Cryptocurrency And NFT Traders Required To File A T1135 Form?

Content Components Of Foreign Accrual Property Income – Canadian Income Tax – Toronto Tax Lawyer Guide

Content Foreign Affiliates And Controlled Foreign Affiliates – Canadian Income Tax – Toronto Tax Lawyer Guide

Content Withholding Tax On Non-Resident Reimbursements And Remuneration

Content Foreign Buyer Tax Survives Constitutional Challenge

Content T1134 Canadian Income Tax Form: Toronto Tax Lawyer’s Guide

Content 2021 Updates For T1134: Canadian Tax Lawyer’s Perspective

Content Specified Foreign Property: Canadian Tax Lawyer’s Guide

Content Maple Leafs GM Vs CRA Tax Court Ruling: Canadian Tax Lawyer Guide

Content T1135: Interests In Non-Resident Trusts Not Acquired For Consideration

Content How Does Canada Tax Non-Resident Pro Athletes

Content Canada-US Tax Treaty

Content U.S. Profits Interests

Content 1074022 B.C. Ltd. v. Li – Misinterpretation Of Section 116

Content Tax Treaties

Content Tax Treatment Of US-Owned Canadian ULC – A Toronto Tax Lawyer Analysis

Content B2B Loans

Content Non Resident Tax Returns

Content Tax Evasion, Money Laundering

Content The Canadian Taxation Implications For Individual Non-Residents Disposing Of Canadian Real Property- Tax Guide By Canadian Tax Lawyer

Content Determining The Residence Of A Corporation For Tax Purposes – A Canadian Tax Lawyer’s Guide

Content Canada’s Foreign Transaction Reporting Rules

Content Non-Resident Carrying on Business in Canada – What is a Business

Content Reporting Requirements for Non-Resident Trusts

Content T1134 Form for Foreign Affiliates

Content Penalty for not Filing T1135

Content Offshore Asset Reporting Requirements to file T1135

Content Business by a Non-Resident in Canada

Content Transfer Pricing

Content Transfer Pricing Documentation

GST/HST

Content The Ultimate Guide To Offshore Reporting Requirements Of CRA’s Voluntary Disclosures Program (VDP)

Content CRA Uses ‘Alternative Methods’ For GST/HST Audits, Including Estimating Business Revenue, Reconstructing Missing Receipts

Content The GST/HST New Housing Rebate: A Complete Guide To Eligibility, Amounts, And How To Avoid Case Law Traps

Content Zero-Rated vs. Exempt Supplies: A GST/HST Classification Checklist For Business Owners

Content No GST/HST New Housing Rebate Where A Bare Trusee Takes Title

Content Sex Worker GST Returns

Content When CRA Denies New Housing Rebate Claim: Sharma v The King , 2025 TCC 145

Content When CRA Denies The GST/HST New Housing Rebate: Lessons From Xian v The King, 2026 TCC 122 On Proving A Primary Residence

Content Public Service Bodies Beware: Why Reimbursements For Certain Contractual Employee Benefits May Not Qualify For GST/HST Rebates

Content Zhen Zhen Fashion Company Ltd. v. The King (2026 TCC 124): Disorganized Records Sink An Input Tax Credit Claim, But Save The Taxpayer From Gross-Negligence Penalties

Content Do You Have To Pay GST When You Build And Sell A House? Does The Evidence Support A Permanent Residence, Or A House To Be Sold For Profit?

Content Quebec Entrepreneur Jailed And Ordered To Pay Over $1 Million For GST/QST Fraud – Canadian Tax Lawyer Analysis

Content What Is The CRA's GST/HST Voluntary Disclosures Program?

Content GST/HST Tax Court Success: Persistent Litigation Eliminates Gross-Negligence Penalties And Delivers Significant Tax Savings

Content How Section 296(2) Saves Expired GST/HST Input Tax Credits: Why The Ontario Tire Stewardship Case Is A Big Win For Businesses

Content Qureshi v. The King -Pre-Construction Condominium Flipping, Principal Residence Claims, And GST Builder Liability – Tax Court Rejects Taxpayer’s Attempt To Treat $456,000 Profit As Tax-Free

Content BMLex Avocats Inc. v. The King, 2026 CCI 107 – GST/HST Installment Interest Despite A Tax Credit? Tax Court Confirms That Taxpayers Must Provide Clear Instructions To Apply Refund Balances

Content The Complete Guide To The New Canada Groceries And Essentials Benefit (CGEB): Eligibility, Payment Dates, CRA Rules, And Taxpayer Rights

Content The Condo Flipping Trap: Why Tax Court Confirms 100% Of Profits Is Business Income Under Canada’s Real Estate Flipping Tax Rules In Qureshi v. The King

Content Fadali v The King, 2026 TCC 86: When A New Home Sale Becomes A GST/HST Problem For The Builder

Content Director Liability For $700,000 Of Unremitted GST/HST: A Canadian Tax Lawyer Breaks Down Stevens v. The King

Content GST/HST On Medical Fee-Sharing: Canadian Tax Lawyer Explains Why CRA Lost In Tax Court In MedSleep v. The King

Content Why Tax Court Won’t Reopen GST Appeals Dropped By Mistake: Canadian Tax Lawyer Explains Yi v The King (2026 TCC 82)

Content Real Estate Investors Beware: When GST Exemption On Properties Doesn’t Apply, Explains Canadian Tax Lawyer, Moseley v. The King (2026 TCC 59)

Content Director’s Liability For Taxes: A Canadian Tax Lawyer’s Guide To CRA Rules

Content Beware The Tax Trap: When Exactly Does A Business Cease To Qualify As A “Small Supplier” And Lose GST/HST Exemption?

Content GST/HST Bad Debt Deductions Denied For Failing To Meet Strict Statutory Requirements, Heydary Green Professional Corporation v. The King

Content Case Comment: Recent Tax Court Decision Balances CRA’s Broad Reassessment Powers While Placing Limits On Gross Negligence Penalties, 3278735 Nova Scotia Limited v His Majesty The King, 2026 TCC 65

Content Bergevin v. The Queen – Missed A Tax Deadline? Disaster! The Courts Are Very Strict With Procedural Rules

Content Charging GST/HST On Digital Marketing Income In Canada: AdSense, NFTs, And Zero-Rating Risks

Content Ambiguous HST Clauses In Real Estate Transactions: When “Tax Included” Means Risk Assumed

Content Case Comment – Heritage Square Retirement Living Inc. v The King, 2026 TCC 39

Content Tax Court Of Canada Overturns CRA’s Denial Of GST/HST Input Tax Credits: Fiera Foods Company v The King

Content GST Carousel Fraud Not A Fun Ride When CRA Catches Up To You – Guidance From A Canadian Tax Lawyer

Content Amex Bank Of Canada v. The King (2026 FCA): Federal Court Of Appeal Confirms GST/HST Input Tax Credits Cannot Be Recovered For Credit-Card Loyalty Rewards Programs In Exempt Canadian Financial Services

Content If A Company Is Revived, Are Former Directors Liable For Unpaid GST Again? Maragos v. The King (2026 TCC 4)

Content Sharma v. The King – Tax Court Of Canada Upholds GST/HST New Housing Rebate Despite Short Ownership Period

Content Talukdar v. The King – When Credible Oral Evidence, Not Perfect Records, Determines Entitlement To The GST/HST Rebate For New Housing

Content Caddell v. The King – When Fair Market Value, Not Intention, Determines Whether GST Applies To Cost Of A Self-Supply Housing

Content How GST Exemptions Work In First Nations’ Commerce: Commentary On Canada v. LBL Holdings Limited (2025 FCA 186)

Content Gaitanis v. The King – When Intention, Ownership, And "Family Assistance” Are Not Enough To Secure The GST/HST New Housing Rebate

Content When An Oral CRA Refusal Becomes A Reviewable Administrative Decision: Hillcore Financial Corporation v Attorney General Of Canada

Content Boylu v. The King (2025 TCC 192) – Uber, Small Suppliers, Other Gig-Economy Workers: What The CRA Must Prove To Enforce HST And Input Tax Credits (ITCs)

Content Commercial Land Developers: Use Caution When Registering Rental Buildings As Condominiums, As GST/HST May Apply: Cautionary Tale Of Carvest Properties Limited v. The King (2025 TCC 166)

Content Directors Beware: CRA Can Come After You For Unpaid Source Deductions

Content Ng v. The King (2025 TCC 172) – Missing A CRA Notice Is Not An Excuse: Tax Court Reinforces Strict Deadlines To GST Objections

Content Canada’s GST/HST Reverse Charge Mechanism (RSM) 2025: Complete Guide For Telecom Providers, Telecom Resellers Facing New Anti-Carousel Fraud

Content What Every Landlord Must Know About The Residential Rental Property (RRP) Rebate

Content When Is GST/HST Payable On Vehicle Sales? Guidance From A Canadian Tax Lawyer

Content Canada's August 2025 Draft Legislation: What Crypto Investors Need To Know Now

Content Statute-Barred Years For GST/HST Returns: When The CRA Can Reassess And How To Protect Your Rights

Content Canada Updates Voluntary Disclosure Program (VDP) For GST/HST: New Rules Take Effect October 1, 2025

Content Why 'Primary Residence Intent’ Matters To Residential Real Estate Owners, Investors: GST/HST New Housing Rebate – Lisi v. The King (2025 TCC 106)

Content First-Time Buying A Home In Canada: Essential Tax Incentives And Rebates You Should Know

Content How NOT To Apply For GST/HST Rebate For Owner-built Homes: Case Commentary On Charleboix v HMK

Content MedSleep Inc v The King – Sleep Clinic Wrongly Assessed For Failing To Pay GST/HST For Providing Services To Its Doctors Because It Was 'Exempt Supply’

Content The GST/HST Implications Of Changing The Use Of Personal Property – How Subsections 199(3), 200(2), And 200(3) Interact

Content Case Commentary: Osman v The King – GST/HST New Housing Rebate Claim Denied Due To Lack Of Intention To Occupy Property First

Content House-Flippers Beware: You Are Not Eligible For GST/HST New Housing Rebates – Ram V HMK, 2025 TCC 49

Content Builders Beware: GST/HST Now Applies On All ‘Assignment Sales’ (Pre-Construction Contracts) – Guidance From A Canadian Tax Lawyer

Content Case Study: How Rotfleisch & Samulovitch Helped Reduce The Tax Owed By ON Corp To CRA From $140,000 To $3,000

Content Case Commentary: Ayoub v The King, 2025 TCC 48 – Beware Home Builders Must Pay HST/GST When Renting Or Using Property Personally (Self-Supply Rule)

Content Case Commentary: 1351231 Ontario Inc. v The King – Why GST/HST Must Be Paid On The Sale Of A Residential Unit Used For Airbnb

Content South Africa Is Ramping Up Its Crypto Tax Reporting Compliance Programs

Content Builders Of Real Property Are Liable For GST/HST Tax Payments

Content Deemed Self-Assessment After GST/HST Number Cancellation

Content Director's And Officer's Tax Liability When Serving On Boards—And Resigning To Prevent Corporate Tax Liability

Content Tax Trap For Canadian Landlords: Temporary Use Of A Long-Term-Rental Property As An Airbnb May Trigger Unanticipated GST/HST Upon Sale

Content Case Study: Canadian Crypto-Tax Lawyers Save Bitcoin Millionaire From Criminal Prosecution For Tax Evasion

Content Charging GST/HST: A Single Supply vs Multiple Supplies – Canadian Tax Lawyer Explains The Difference

Content Canadian Tax Guide For Uber, Lyft, UberEats, DoorDash, Grubhub & Postmates Drivers: Income Tax & GST/HST Obligations For Commercial Ridesharing And Delivery Services

Content Sale Of Long-Term Rental Property Results In $80,000 GST/HST Owing Because Of Airbnb Use Before Sale: 1351231 Ontario Inc. v. The King, 2024 TCC 37

Content Case Commentary: Litman v. The King – Does Building Laneway Houses Qualify For The New Housing Tax Rebate Under Subsection 256(2) Of The Excise Tax Act?

Content Canadian Residential Real Estate Developers: Beware The Tax Trap Of GST/HST Deemed ‘Self-Supply’ Rules

Content Changes Are Coming To Crypto Asset Reporting Framework (CARF), To Crackdown On Tax Evasion: Federal Budget 2024

Content A Canadian Tax Lawyer’s Case Commentary On Fiera Foods Company v HMK, 2023 TCC 140: Documentation For HST/GST Does Not Need To Follow Pre-Set Or Prescribed Format By CRA

Content Case Commentary: Director Held Personally Liable For Unremitted And Uncollected GST/HST, 'Due Diligence’ Defence Judged Insufficient – Hall v The King (2023)

Content Case Commentary: GST/HST Not Owing On Renovation Because Definition Of "Substantial Renovations" Of Property Not Met – 2437299 Ontario Inc. vs. The King

Content How A Homeowner Fought The CRA Over The Denied New Housing Rebate—and Won: Simonetta v. The King

Content Tax Fraud And Tax Evasion In The Same Case: A Rotfleisch & Samulovitch Analysis Of Regina V Reynolds – Violations Of The Income Tax Act, Excise Tax Act, And Criminal Code Of Canada

Content Warning For Canadian Businesses: The CRA Is Not Sympathetic To Victims Of GST/HST Tax Fraud; The Onus Is On Canadian Taxpayers To Protect Their Businesses From VAT Fraud

Content When CRA Wrongly Denies Input Tax Credits (ITCs) For Businesses That Use Agents: A Canadian GST/HST Tax Trap

Content Canada Revenue Agency (CRA) Requires Written Indication To Claim Input Tax Credits (ITCs) On Rebates From Manufacturers, Distributors

Content Proposed Amendments To GST/HST Rules For Cryptocurrency Mining: What’s Covered And What’s Not

Content New Housing Rebate: Guidance From A Canadian Tax Lawyer On The Issue Of Primary Place Of Residence

Content Tax Trap For Canadian NFT Traders, NFT Artists & NFT Content Creators: You Must Obtain Proper Records If You Want To Claim Input Tax Credits

Content Canadian GST/HST Tax Trap: ITC Record-Keeping Requirements For Canadian Businesses

Content Canada Proposes New GST/HST Rules For Cryptocurrency Mining – Canadian Tax Guidance From A Canadian Tax Lawyer

Content Soulliere v The Queen: Director’s Liability For Unpaid Taxes

Content Director Hit With Vicarious Tax Liability: Cliff v The Queen, 2022 FCA 16 – A Canadian Tax Lawyer’s Analysis

Content Financial Service As An Exempt Supply From GST/HST – Guidance From A Canadian Tax Lawyer To Applewood Holdings Inc. v The Queen

Content A Canadian Tax Lawyer’s Guidance On GST/HST On Shareholder Benefits

Content Reeves v The Queen & Applicability Of The GST/HST New Housing Rebate

Content Gay-Ann Reeves Case Comment

Content A Canadian Tax Lawyer’s Guide On Bill C-30 Amendment To The Excise Tax Act – GST/HST Implications For Cryptocurrency Transactions

Content Taxable Sale Of Real Property By A Non-Registrant And Subsection 257(1) Of The Excise Tax Act – Canadian Tax Lawyer GST/HST Guidance

Content A Canadian Tax Lawyer’s Scary Taxes For Halloween

Content A Canadian Tax Lawyer’s Perspective On GST/HST And Constructive Importers

Content A Canadian Tax Lawyer’s Perspective On Incoterms ® And GST/HST Taxation

Content GST/HST & Agent Disbursements: Canadian Tax Lawyer’s Guide

Content Federal Court Of Appeal: Aeroplan Promos To CIBC Subject To GST

Content Canada Export Distribution Centre Program: Toronto Tax Lawyer’s Guide

Content GST/HST Digital Service Tax Requirements: Non-Resident Businesses

Content GST/HST Zero-Rated & Exempt Supplies: Canadian Tax Lawyer’s Guide

Content GST/HST Director’s Liability: Canadian Tax Lawyer’s Guide

Content Federal Court On VISA Supplying Financial Services: Tax Guidance

Content Input Tax Credits: Introduction By Canadian GST/HST Tax Lawyer

Content Real Estate Assignment

Content Voluntary Registration For GST/HST As A Small Supplier

Content GST/HST Non-Resident Override Rule

Content Objections And Appeals By Specified Persons

Content R. v. Scholz — Document Forging And Tax Fraud

Content Goods And Services Tax

Content Retroactive GST/HST Registration

Content ITCs And Accommodation Invoices

Content Subsection 156(2) Of The Excise Tax Act

Content Commercial Rent Deferrals And Covid-19

Content GST/HST Liability For Directors

Content GST/HST, Wash Transactions

Content 2237065 Ontario Inc

Content Singh v R

Content GST/HST Gross Negligence Penalties

Content GST/HST Section 167 Sale Of A Business Election – Toronto Tax Lawyer Analysis

Content A Canadian Tax Lawyer’s Commentary On South Dakota V wayfair, Inc Et Al: Winter Is Coming For Online Retailers

Content The GST/HST Self-Supply Rules For Builders Of Residential Homes, Condominiums, And Apartment Buildings – A Canadian Tax Lawyer’s Analysis

Content Bad Debt GST Refund – Excise Tax Implication Of Bad Debt Write-Offs – Toronto Tax Lawyer Analysis

Content No GST/HST New Housing Rebate Where a Bare Trustee Takes Title

Content No GST/HST New Housing Rebate Where a Bare Trustee Takes Title

Content Non-Resident Rebate for GST/HST on Export of Commercial Goods

Content Treatment of GST/HST Under the Proposed VDP Changes

Content GST/HST Tax Audit ? Builders of Residential Real Property and Self-Supply

Content Taxation of Commercial Ride Sharing – New GST/HST Obligations

Content Limits on CRA Collections – GST/HST

Content Interlining Transportation Services and Input Tax Credits – GST/HST

Content Quick Method of Accounting ITCs on GST/HST Tax Returns

Content Zero-rated and Exempt Supplies for GST/HST

Content Exports Receive Favorable GST/HST Treatment

Content GST/HST on Amalgamations

Content Simplified Method for Claiming Input Tax Credits (ITCs)

Content Goods & Services Tax (GST) & Harmonized Sales Tax (HST)

Content Goods and Sales Tax and Harmonized Sales Tax (GST/HST) Registration Requirements

Content New Housing Rebates – GST/HST Refunds

Content H.S.T. – What Small Business Needs to Know

Municipal Taxation

Content How To Appeal The Toronto Vacant Home (VHT) Tax: Here’s What One Landlord Did To Fight VHT Assessment

Content Landlords With Tenant-Occupied Properties, Beware: How The City Collects Unpaid Utility Bills, Toronto Property Tax Bills, And Other Transferred Charges

Content Vacant Home Tax 2026 Update: Exemptions, Appeals, Deadlines, Audits, And How To Challenge A Vacant Home Tax Assessment

Content Toronto’s Vacant Home Tax: A Complete Guide To Tax Exemptions, Tax Appeals, And Tax Compliance For Toronto Property Owners

Content Offshore Asset Reporting

Content Reporting Offshore Income

Content Tax Return Filing Requirements

Property Taxation

Content Landlords With Tenant-Occupied Properties, Beware: How The City Collects Unpaid Utility Bills, Toronto Property Tax Bills, And Other Transferred Charges

Vacant Housing Tax

Content How To Appeal The Toronto Vacant Home (VHT) Tax: Here’s What One Landlord Did To Fight VHT Assessment

Content Vacant Home Tax 2026 Update: Exemptions, Appeals, Deadlines, Audits, And How To Challenge A Vacant Home Tax Assessment

Content Toronto’s Vacant Home Tax: A Complete Guide To Tax Exemptions, Tax Appeals, And Tax Compliance For Toronto Property Owners

Provincial Taxation

Content How to Claim the Ontario Nominee Exemption of the Ontario Non-Resident Speculation Tax (NRST) – Toronto Tax Lawyer Guide

Content Why Ontario Employer Health Tax (EHT) Assessment Disputes Frequently Escalate Into Tax Litigation: EHT Rules, Tax Audit Risk, And EHT Appeals

Content A Primer On The Ontario Land Transfer Tax Including Gifts, Exemptions, Rebates By A Canadian Tax Lawyer

Content A Canadian Tax Lawyer's Guide To Ontario Foreign Buyer Tax

Content 2021 Ontario Fall Economic Update: Canadian Tax Lawyer's Guidance

Content Ontario Employer Health Tax (EHT): Canadian Tax Lawyer’s Guidance

Content Quebec Now Requires Disclosure Of Specified Transactions

Content NRST Foreign National Worker's Rebate

Content Non-Resident Withholding Tax – Interest Income – A Toronto Tax Lawyer Analysis

Content Ontario Non-Resident Speculation Tax

Content EHTA & Employee v Contractor

Content Ontario Non-Resident Speculation Tax

Content Changes to Ontario Business Corporations Act and the New Forfeited Corporate Properties Act

Changes to OBCA

Content Ontario Non-Resident Speculation Tax

Content Changes to Ontario Business Corporations Act and the New Forfeited Corporate Properties Act

Employer health tax

Content EHTA & Employee v Contractor

Land Transfer Tax

Content A Primer On The Ontario Land Transfer Tax Including Gifts, Exemptions, Rebates By A Canadian Tax Lawyer

Nonresident Speculation Tax

Content How to Claim the Ontario Nominee Exemption of the Ontario Non-Resident Speculation Tax (NRST) – Toronto Tax Lawyer Guide

Content Non-Resident Withholding Tax – Interest Income – A Toronto Tax Lawyer Analysis

Ontario taxation

Content How to Claim the Ontario Nominee Exemption of the Ontario Non-Resident Speculation Tax (NRST) – Toronto Tax Lawyer Guide

Content Why Ontario Employer Health Tax (EHT) Assessment Disputes Frequently Escalate Into Tax Litigation: EHT Rules, Tax Audit Risk, And EHT Appeals

Content A Canadian Tax Lawyer's Guide To Ontario Foreign Buyer Tax

Content 2021 Ontario Fall Economic Update: Canadian Tax Lawyer's Guidance

Content Ontario Employer Health Tax (EHT): Canadian Tax Lawyer’s Guidance

Content NRST Foreign National Worker's Rebate

Content Ontario Non-Resident Speculation Tax

Québec taxation

Content Quebec Now Requires Disclosure Of Specified Transactions

Corporate Taxation

Content Beware Of Tax Implications When A Canadian Corporation Emigrates: Departure Tax, Corporate Emigration Tax, And More

Content Director’s Liability For Taxes: A Canadian Tax Lawyer’s Guide To CRA Rules

Content Revival For Tax Purposes: When Is It Necessary For A Dissolved Corporation?

Content Directors Beware: CRA Can Come After You For Unpaid Source Deductions

Content A Primer On Tax Rules For Syndicates: Courts Look Beyond Roles To Purpose, Profit

Content Improve Your Understanding Of Not-For-Profit Status In Canada: What Qualifies And What Doesn’t, Plus Tax Benefits

Content Share Redemption And Share Retraction: Tax Treatment By CRA—plus They Are Useful Tax Planning Tools

Content Director's And Officer's Tax Liability When Serving On Boards—And Resigning To Prevent Corporate Tax Liability

Content When Can A Non-Profit Organization Turn A Profit? The "Profit-Purpose” Test For Non-Profit Organizations’ Tax-Exempt Status Under The Canadian Income Tax Act

Content Tax Fraud And Tax Evasion In The Same Case: A Rotfleisch & Samulovitch Analysis Of Regina V Reynolds – Violations Of The Income Tax Act, Excise Tax Act, And Criminal Code Of Canada

Content Soulliere v The Queen: Director’s Liability For Unpaid Taxes

Content Director Hit With Vicarious Tax Liability: Cliff v The Queen, 2022 FCA 16 – A Canadian Tax Lawyer’s Analysis

Content Zvilna v. Canada: Director’s Liability For Unpaid Taxes: A Canadian Tax Lawyer’s Note Of Caution To Directors

Content Case Analysis Tran V Queen On Demolishing The Minister’s Assumption In An Income Tax Section 227.1 Director’s Liability Case – Toronto Tax Lawyer Guide

Content Changing Of Corporation’s Fiscal Period: Toronto Tax Lawyer’s Guide

Content Qualifying For Small Business Deduction: Canadian Tax Lawyer’s Guide

Content Taxation For Non-Profit Organizations

Content GST/HST Director’s Liability: Canadian Tax Lawyer’s Guide

Content Director’s Liability Limitation Period

Content Changes To Business Corporations Act

Content Director’s Liability Soulliere v The Queen

Content Duque v. The Queen And Director Liability

Content The Queen v Colitto – Clarity To Directors’ Liability

Content Functional Currency Election

Content Hamad v. The Queen: Due Diligence

Content Tax Clearance Certificates

Content Ceasing Directorship

Content Safe Income On Hand – Paying Tax Free Inter-Corporate Dividends

Content Ceasing To Be A Director – Directors’ Liability For Tax – Toronto Tax Lawyer Analysis

Content 2018 Federal Budget - Passive Income in Corps - A Toronto Tax Lawyer Analysis

Content 2018 Federal Budget - Passive Income in Corporations

Content Dividend Types under the Canadian Income Tax Act

Content Tax Free Capital Dividends – Elections and Penalties

Content Taxation of Shareholder Loans

Content Tax Integration Mechanisms: Refundable Dividend Tax On Hand (RDTOH), Aggregate Investment Income & the Part IV Tax

Corporate Directors

Content Soulliere v The Queen: Director’s Liability For Unpaid Taxes

Content Zvilna v. Canada: Director’s Liability For Unpaid Taxes: A Canadian Tax Lawyer’s Note Of Caution To Directors

Content Changes To Business Corporations Act

Content Hamad v. The Queen: Due Diligence

Content Ceasing Directorship

Content Ceasing To Be A Director – Directors’ Liability For Tax – Toronto Tax Lawyer Analysis

Corporate dissolution

Content Revival For Tax Purposes: When Is It Necessary For A Dissolved Corporation?

Content Tax Clearance Certificates

Corporate Emigration

Content Beware Of Tax Implications When A Canadian Corporation Emigrates: Departure Tax, Corporate Emigration Tax, And More

Director Liability

Content Director’s Liability For Taxes: A Canadian Tax Lawyer’s Guide To CRA Rules

Content Directors Beware: CRA Can Come After You For Unpaid Source Deductions

Content Director's And Officer's Tax Liability When Serving On Boards—And Resigning To Prevent Corporate Tax Liability

Content Tax Fraud And Tax Evasion In The Same Case: A Rotfleisch & Samulovitch Analysis Of Regina V Reynolds – Violations Of The Income Tax Act, Excise Tax Act, And Criminal Code Of Canada

Content Soulliere v The Queen: Director’s Liability For Unpaid Taxes

Content Director Hit With Vicarious Tax Liability: Cliff v The Queen, 2022 FCA 16 – A Canadian Tax Lawyer’s Analysis

Content Zvilna v. Canada: Director’s Liability For Unpaid Taxes: A Canadian Tax Lawyer’s Note Of Caution To Directors

Content Case Analysis Tran V Queen On Demolishing The Minister’s Assumption In An Income Tax Section 227.1 Director’s Liability Case – Toronto Tax Lawyer Guide

Content GST/HST Director’s Liability: Canadian Tax Lawyer’s Guide

Content Director’s Liability Limitation Period

Content Director’s Liability Soulliere v The Queen

Content Duque v. The Queen And Director Liability

Content The Queen v Colitto – Clarity To Directors’ Liability

General

Content Share Redemption And Share Retraction: Tax Treatment By CRA—plus They Are Useful Tax Planning Tools

Content Changing Of Corporation’s Fiscal Period: Toronto Tax Lawyer’s Guide

Content Qualifying For Small Business Deduction: Canadian Tax Lawyer’s Guide

Content Changes To Business Corporations Act

Content Functional Currency Election

Content Safe Income On Hand – Paying Tax Free Inter-Corporate Dividends

Not-for-profit corporation

Content Improve Your Understanding Of Not-For-Profit Status In Canada: What Qualifies And What Doesn’t, Plus Tax Benefits

Content When Can A Non-Profit Organization Turn A Profit? The "Profit-Purpose” Test For Non-Profit Organizations’ Tax-Exempt Status Under The Canadian Income Tax Act

Content Taxation For Non-Profit Organizations

Taxation of Syndicates

Content A Primer On Tax Rules For Syndicates: Courts Look Beyond Roles To Purpose, Profit

COVID-19

Content US-Canada Employee COVID-19 Guidelines: Toronto Tax Lawyer Guide

Content Covid-19 Pandemic – Tax Limitation Periods To Be Extended

Content Tax Audits Of COVID-19

Content Witnessing Wills Ontario During Covid-19

CCPC

Content How To Leverage The Tax Benefits Of Canadian-Controlled Private Corporation (CCPC) Structure For Emerging, High-Growth Companies

Content How To Use BVI Or Other Offshore Non-CCPCs

General rules

Content How To Leverage The Tax Benefits Of Canadian-Controlled Private Corporation (CCPC) Structure For Emerging, High-Growth Companies

Offshore investment

Content How To Use BVI Or Other Offshore Non-CCPCs

Taxation of Immigrants

Content How Canadian Businesses Are Taxed: A Canadian Tax Lawyer Explains Benefits, Taxes, And Credits To Business Immigrants, Immigrant Investors

Content How The Canadian Taxation System Works Part II: A Canadian Tax Lawyer Explains Benefits, Taxes, And Credits To Tech Worker Immigrants, Newcomers

Content How The Canadian Taxation System Works: A Canadian Tax Lawyer Explains Benefits, Taxes, And Credits To Immigrants, Newcomers

Taxation of Canadian immigrants

Content How Canadian Businesses Are Taxed: A Canadian Tax Lawyer Explains Benefits, Taxes, And Credits To Business Immigrants, Immigrant Investors

Content How The Canadian Taxation System Works Part II: A Canadian Tax Lawyer Explains Benefits, Taxes, And Credits To Tech Worker Immigrants, Newcomers

Content How The Canadian Taxation System Works: A Canadian Tax Lawyer Explains Benefits, Taxes, And Credits To Immigrants, Newcomers

Customs

Content A Canadian Tax Lawyer’s Guide To Get Ready For Delayed Canadian Border Services Agency Assessment And Revenue Management (CARM 2)

Tax Benefits

Content How CRA Calculates Taxes When You Take Personal Trips In Your Employer’s Car

Content Are You Entitled To Receive The Canada Child Benefit (CCB)? ‘Tax Residence’ Is Key, Plus How To Determine If You’re Tax Resident

US Taxation

Content GENIUS Act Crypto Tax Guide 2025-2026: What US Investors, Businesses, And Taxpayers Need To Know About The New Stablecoin Law, Form 1099-DA, And Digital Asset Regulation

Content IRS To Cut Penalties In Overhauled Criminal Voluntary Disclosure Program

Content IRS Quietly Ends The Delinquent FBAR Submission Procedures: What American Taxpayers With Unreported Foreign Accounts Should Do Now

Content U.S. State Tax Amnesty Programs In Mid-2026: What Businesses And Multistate Taxpayers Need To Know To Avoid Penalties

Content Indiana Tax Amnesty 2026: Deadlines, Eligibility Rules, And How To Resolve Indiana Back Taxes Before September 9

Content FIFA World Cup 2026 And US Tax: What American Homeowners, Residents, Foreign Nationals, And Athletes Need To Know

Content Texas Appeals Court Rules El Paso Environmental Franchise Fee An Illegal Tax Without Proper Municipal Tax Authority: Residents May Be Owed Refunds

Content How The IRS Uses Artificial Intelligence In U.S. Tax Audits

Content Panama Papers 10th Anniversary: U.S. Tax Implications, IRS Results & Compliance Lessons For American Taxpayers

Content IRS Reporting Requirements For Foreign Exchange Bureaus: Your Complete BSA Compliance Guide For Currency Exchange Businesses

Content What Are The IRS Digital Asset Reporting Rules (2026)? Form 1099-DA, Crypto Tax Compliance, & IRS Enforcement Risks On Crypto Currencies

Content Indiana Expands Tax Amnesty Program: New Law Adds Additional Eligible Tax Periods For Resolving Back Taxes

Content Los Angeles Proposes Cannabis Tax Amnesty: What Marijuana Businesses Need To Know Now About IRS Tax Risks, Section 280E Compliance, And Cannabis Tax Planning

Content IRS Service Levels For The 2026 Tax Filing Season: What Recent IRS Performance Means For U.S. Taxpayers

Content How American 'Jock Tax’ And State Income Tax Affect NFL Players, Other Professional Athletes: The Sam Darnold Super Bowl Example

Content How U.S. Businesses Can Deduct Outrageous Marketing "Loss Leaders” Expenses On Their Taxes: Lessons From A $3.2 Million Bluefin Tuna Purchase

Content What American Taxpayers Need To Know About IRS Employee Misconduct, Confidentiality Breaches, And Governance Accountability

Content Importing Or Exporting More Than $10,000 In Cash? U.S. Reporting Laws, Federal Penalties, And Disclosure Considerations

Content How To Ensure Compliance With Spot Exchange Rate Requirements Under U.S. Federal Tax Law

Content U.S. Multinational Corporations Achieve Critical Exemption In OECD Global Minimum Tax

Content SECURE 2.0: Key Provisions And Tax Planning Implications For American Retirees

Content IRS Criminal Voluntary Disclosure Program (VDP) Changes Take Effect In Early 2026: How Crypto Tax Disclosures And FATCA Reporting Obligations Affect U.S. Tax Compliance

Content How Cryptocurrency Losses Are Taxed In The United States And Canada: Capital Losses vs Business Losses, Respectively

Content U.S. Cryptocurrency Tax Losses And Business-Style Trading: How Ordinary Loss And Capital Loss Are Treated Under U.S. Tax Law

Content How The IRS Handles Tax-Free Corporate Distributions Under U.S. Tax Law

Content New Hampshire Tax Amnesty Program: A Limited-Time Opportunity To Resolve State Tax Debt

Content IRS Voluntary Disclosure Program 2026 Changes: Seeking Public Input On Tax Compliance For US Taxpayers And US Crypto Investors

Content Maryland Digital Advertising Gross Revenue Tax (DAT) Update: Federal Court Invalidates Pass-Through Ban In Pivotal US Tax Development

Content When CRA And Revenu Québec Tax Audits Turn Into Criminal Investigations: Insights From Gravel v. Agence Du Revenu Du Québec

Content IRS Math And Taxpayer Help Act: Helping American Taxpayers By Making Honest Tax Mistakes Easier To Fix

Content IRS Ends Direct File: What U.S. Taxpayers Need To Know For The 2026 Filing Season

Content 401(k) And IRA Contribution Limits For 2026: Retirement Savings, Adjustments For Inflation, And SECURE 2.0 Changes American Taxpayers Must Know About

Content Italy’s Rising Tax Evasion Vs The United States’ Is Higher, Even With The Voluntary Disclosure Program (VDP)

Content What Landmark Israeli Transfer Pricing Case, Hexadite Ltd. v. Israel Tax Authority, Means For U.S. Multinationals

Content Economic Substance Doctrine [§7701(o)]: Critical Developments And Policy Implications To Prevent Abuse In U.S. Tax Law

Content Israel’s 2025 Voluntary Disclosure Procedure: Updates And Clarifications For U.S. Taxpayers With Israeli Ties

Content U.S. Life Insurance Withdrawals: Tax Implications And Strategies

Content IRS Reverses Course On DeFi Broker Rule: Impact On U.S. Crypto Investors And DeFi Platforms

Content How Limited Partnerships Are Taxed In The U.S.: Insights, Advantages, And Drawbacks From A U.S. Tax Lawyer

Content Case Comment: CFM Insurance, Inc. v. Commissioner – What American Taxpayers Should Know About How The IRS Views Microcaptive Arrangements v Tax Avoidance Schemes

Content Why Passive Foreign Investment Companies (PFICs) Can Have Severe Tax Consequences: A Guide For U.S. Taxpayers

Content How Americans Must Report 'Spin-Off’ Shares Under Section 355 Of The Internal Revenue Code (IRC) In The U.S.

Content U.S. Reporting Requirements For Cross-Border, Related-Party Transactions: What U.S. Taxpayers Must Know Now For Compliance

Content Comparing The U.S. Voluntary Disclosure Program To Israel’s New Tax Disclosure Plan

Content 401(k) Retirement Plans: Expert Strategies For U.S. Employees And Employers From A U.S. Tax Lawyer

Content The Methanex Case: Implications Of 'Treaty Shopping’ And Consequences On U.S. Tax Planning For Americans

Content Landmark July 2025 U.S. Tax Case: What Taxpayers Need To Know About JM Assets, LP v. Commissioner

Content California State Income Tax Law Changes: What Taxpayers Need To Know For 2025

Content New York State Income Tax Law Updates: What Taxpayers Need To Know For 2025 And Beyond

Content Illinois Announces Fall 2025 Tax Amnesty Program: What Taxpayers Need To Know

Content How American Taxpayers Can Resolve Undeclared Income And Avoid Tax Penalties: Many U.S. States Now Offer Tax Amnesty Programs

Content Latest Developments In U.S. Taxation Of Cryptocurrency: What American Crypto Traders, Crypto Investors Need To Know Now

Content How U.S. Commercial Real Estate Investors Can Best Leverage’ Nonrecognition Tax Transactions’ To Defer Tax

Content Three Recent U.S. Tax Evasion Prosecutions: Bitcoin, Payroll Taxes, And Yoga Empire

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