Canada: Tax Authorities

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

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

In Mann v. The King, 2023 TCC 151, the Tax Court of Canada reaffirmed the Canada Revenue Agency's (CRA) authority to use the net worth method under subsection 152(7) of the Income Tax Act when a taxpayer fails to keep adequate books and records.

RS

Rotfleisch & Samulovitch P.C.

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

A Voluntary Disclosure Application, also commonly known as a VDP application in Canada, is a formal process administered by the CRA that allows Canadian taxpayers to correct previously inaccurate or incomplete information...

RS

Rotfleisch & Samulovitch P.C.

Legislative Update Report No. 2025-14 Le Bulletin D'actualités Législatives

Osler's Legislative Update is a bi-weekly listing of new legislation. This issue covers legislation for the period 07/10 to 07/23...

Canada Government

OH

Osler, Hoskin & Harcourt LLP

From Paper To Portal: Is Your Business Ready For The CRA's Digital-by-Default Mail System?

The Canada Revenue Agency (CRA) has taken a significant step into the digital age by making online mail delivered through the My Business Account portal the default...

BC

Blake, Cassels & Graydon LLP

Climate Change Initiatives: Selected Recent Changes And The Application Of Existing Tax Principles To Clean Energy—Part 2

Canada Environment

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Bennett Jones LLP

Mr. Grenon's Legendary RRSP And Its Implications For Registered Plan Trustees

BL

Borden Ladner Gervais LLP

Mr. Grenon's Legendary RRSP And Its Implications For Fund Manufacturers

BL

Borden Ladner Gervais LLP

Clean Incentives: How Tax Insurance Is Emerging As A Critical Risk Mitigation Tool (Podcast)

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Bennett Jones LLP

The One Big Beautiful Bill Act: Impacts On Canadian Businesses With U.S. Investments

Worldwide Government

TL

Torys LLP

"Until Death Do Us Part": Am I Responsible For My Partner's Tax Bill?

MT

Miller Thomson LLP

CRA Moves To Online Mail For Businesses

MK

Millar Kreklewetz

Major U.S. Tax Legislation Enacted Without Retaliatory Tax Provision

DW

Davies Ward Phillips & Vineberg

A Big Beautiful Betrayal For US Expats. Is Renunciation Of US Citizenship Now The Best (And Only) Option?

MP

Moodys Private Client Law LLP

The One Simple Question All Advisors Must Ask To Save Their Clients From An IRS Nightmare (And Save Them A Call To Their Malpractice Carrier).

MP

Moodys Private Client Law LLP

Overview And Analysis Of The GENIUS Act

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McMillan LLP

Timing Isn't Everything: Termination Upon Return From A Protected Leave Of Absence

Canada Employment

F

Fasken

Ontario Court Comments On AI Competency

Canada Technology

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McCarthy Tétrault LLP

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

RS

Rotfleisch & Samulovitch P.C.

Appointing Someone To Make Health Care Decisions If You Become Unable To

Canada Healthcare

ML

McKercher LLP

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

In Mann v. The King, 2023 TCC 151, the Tax Court of Canada reaffirmed the Canada Revenue Agency's (CRA) authority to use the net worth method under subsection 152(7) of the Income Tax Act when a taxpayer fails to keep adequate books and records.

RS

Rotfleisch & Samulovitch P.C.

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

A Voluntary Disclosure Application, also commonly known as a VDP application in Canada, is a formal process administered by the CRA that allows Canadian taxpayers to correct previously inaccurate or incomplete information...

RS

Rotfleisch & Samulovitch P.C.

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

Leslie Sand of Brooks, Alberta, has been sentenced to 3.5 years in jail and fined nearly $800,000 for defrauding the Canada Revenue Agency (CRA) through fake COVID-19 subsidy claims and tax evasion.

RS

Rotfleisch & Samulovitch P.C.

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

Dealing with the Canada Revenue Agency (CRA) can often feel like navigating a complex maze.

RS

Rotfleisch & Samulovitch P.C.

Settlements: Tax Outcomes Every Litigator Needs To Know

MT

McCarthy Tétrault LLP

Règlements : Les conséquences fiscales que tout plaideur devrait connaître

MT

McCarthy Tétrault LLP

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

RS

Rotfleisch & Samulovitch P.C.

What Is A "Lawful Distribution To The Public" For Tax Purposes?

ML

McMillan LLP

Beneficiary Designations For Registered Accounts: Do You Really Want The Courts To Get Involved?

OE

O'Sullivan Estate Lawyers LLP

Making Sense Of The Recent Canadian Tax Announcements And Proposed U.S. Tax Measures

GW

Gowling WLG

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'

RS

Rotfleisch & Samulovitch P.C.

A Canadian Tax Lawyer's Guide To Changes In Tax Obligations For Trust Executors And Trustees That Will Simplify Estate Administration

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

What's In A Share – Do You Have The Right Share Capital?

MT

Miller Thomson LLP

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

Dealing with the Canada Revenue Agency (CRA) can often feel like navigating a complex maze.

RS

Rotfleisch & Samulovitch P.C.

A Canadian Tax Lawyer's Guide To Changes In Tax Obligations For Trust Executors And Trustees That Will Simplify Estate Administration

Proposed amendments to the Income Tax Act (ITA)will ease the administrative burdens of executors and trustees. It is important to understand these changes as they change the tax obligations of executors and trustees.

RS

Rotfleisch & Samulovitch P.C.

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

In Bank of Nova Scotia v His Majesty the King, the FCA confirmed the Tax Court's decision that arrears interest could accrue until the date of a reassessment, even in situations where a subsequent loss carryback effectively offsets most of the reassessed tax liability.

RS

Rotfleisch & Samulovitch P.C.

What's In A Share – Do You Have The Right Share Capital?

The current economic climate has put a general damper on transactional activity. Many business owners, prospective purchasers and practitioners point to uncertainty...

MT

Miller Thomson LLP

Canada To Rescind Its Digital Services Tax

OH

Osler, Hoskin & Harcourt LLP

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

The Canada Revenue Agency (CRA) has expansive powers to enforce compliance with the Income Tax Act, notably through Section 231.2, which allows the agency to demand documents or information from individuals or entities during a tax audit.

RS

Rotfleisch & Samulovitch P.C.

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

Subsection 231.1(1) of the Income Tax Act (ITA) outlines the powers of CRA during a tax audit or examination. Before the legislative changes in 2022, the text read as follows...

RS

Rotfleisch & Samulovitch P.C.

Tax Me Baby One More Time - Understanding Property Taxes

Let's be honest, no one throws a party when their property tax bill arrives. It is one of those unavoidable parts of our life journey.

SB

Sorbara Law

The Future Of Canadian Pension Governance: Updated Legal Insights

The Canadian regulatory landscape presents a dynamic mix of regulatory, policy and governance updates that demand careful attention from Canadian pension plan sponsors and administrators.

Canada Employment

BC

Blake, Cassels & Graydon LLP

MEGlobal Canada ULC v. The King: When Split Jurisdiction Leaves A Gap In Relief

MT

McCarthy Tétrault LLP

Retaliatory Taxes: Pending Legislation In U.S. Congress May Adversely Impact Returns On Inbound Investment

DW

Davies Ward Phillips & Vineberg

Tax Credits In The Canadian Film Industry: Why Proper Corporate Structuring Matters

MT

Miller Thomson LLP

Crédits D'Impôt Dans L'Industrie Cinématographique Canadienne : L'Importance D'Une Bonne Structuration De L'Entreprise

MT

Miller Thomson LLP

Documentation des crédits de taxe sur les intrants

MT

McCarthy Tétrault LLP

EIFEL Tips And Traps Every Business Should Know For 2025 And Beyond

RS

RSM Canada

SR&ED Policy Changes Raise Compliance Risks For Canadian Businesses

RS

RSM Canada

Canadian Businesses At Risk From Proposed U.S. Tax Changes

RS

RSM Canada

Access Denied: Federal Court Rejects CRA's Applications For Shopify's Information

C

Cassels

Looking To Make 2025 Your Last Year Of Filing US Taxes? Start Your Renunciation Journey Today.

MP

Moodys Private Client Law LLP

Top 10 Tax Tips For Navigating Your Obligations In Canada's Platform Economy

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

IFW April 2025 Newsletter – The Latest News On Changes In Response To U.S. Tariffs

Canada International

IF

Israel Foulon Wong

Input Tax Credit Documentation

MT

McCarthy Tétrault LLP

U.S. Tax Retaliation Measures: What's At Stake For Canada's Investment Sector

BL

Borden Ladner Gervais LLP

See more

Highlighted Content

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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