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Tax Law and International Tax Law

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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.

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

The Supreme Court of Canada’s decision in Stewart v Canada, 2002 SCC 46, represents a foundational shift in Canadian tax law concerning what constitutes a “source of income” under the Income Tax Act.

RS

Rotfleisch & Samulovitch P.C.

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

The creator economy has fundamentally changed how Canadians earn income. YouTubers, Instagram influencers, TikTok personalities, Twitch streamers, podcasters, affiliate marketers, bloggers, online educators, subscription-based performers, and other digital entrepreneurs now generate substantial revenues through online platforms.

RS

Rotfleisch & Samulovitch P.C.

A Complete Guide To The Canada Greener Homes Affordability Program (CGHAP): Tax Implications For Homeowners, Landlords, And Renters

Green retrofits come with real tax consequences. Understanding how the CRA treats CGHAP grants, rental property deductions, ACB adjustments, principal residence exemption interactions, Class 43.1 eligibility, and Quebec provincial tax obligations is essential before you apply.

RS

Rotfleisch & Samulovitch P.C.

When Can Your Crypto Losses Become Tax Deductions? A Canadian Tax Lawyer On Capital Losses vs Business Losses

Crypto losses are not all deductible in the same way. In Canada, the core question is not simply whether a taxpayer lost money on Bitcoin, Ether, Tao or another token.

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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)

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

The Complete Guide To The New Canada Groceries And Essentials Benefit (CGEB): Eligibility, Payment Dates, CRA Rules, And Taxpayer Rights

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

IRS 45Z Hearing Recap: What Treasury’s Questions Signal For The Final Clean Fuel Credit Rule

B

Bracewell

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Webinars

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Recorded on 20 Jan 2026 | 3:00 PM

2026 Canadian In-House Counsel Report: Unparalleled Insights into Canada's In-House Profession from CBA In-House Lawyers

TC

CBA In-House Lawyers

Recorded on 9 Jul 2025 | 2:00 PM

Digital Assets – Innovation vs Compliance: Emerging Offshore Jurisdictional Trends – How Legal Advisers' Roles Will Change

W

Walkers

Recorded on 24 Jun 2025 | 3:00 PM

(2nd Session) 2025 Global In-House Counsel Survey Report: Unique Insights into the Global In-House Counsel Profession

IC

In-House Counsel Worldwide

Recorded on 24 Jun 2025 | 9:00 AM

(1st Session) 2025 Global In-House Counsel Survey Report: Unique Insights into the Global In-House Counsel Profession

IC

In-House Counsel Worldwide

Highlighted 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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

A Complete Guide To The Canada Greener Homes Affordability Program (CGHAP): Tax Implications For Homeowners, Landlords, And Renters

RS

Rotfleisch & Samulovitch P.C.

When Can Your Crypto Losses Become Tax Deductions? A Canadian Tax Lawyer On Capital Losses vs Business Losses

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

King Charles Taxation And Canadian Comparisons: Voluntary Compliance, Crown Privilege, And Tax Transparency

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

Capital Gains Tax

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

The Supreme Court of Canada’s decision in Stewart v Canada, 2002 SCC 46, represents a foundational shift in Canadian tax law concerning what constitutes a “source of income” under the Income Tax Act.

RS

Rotfleisch & Samulovitch P.C.

A Complete Guide To The Canada Greener Homes Affordability Program (CGHAP): Tax Implications For Homeowners, Landlords, And Renters

Green retrofits come with real tax consequences. Understanding how the CRA treats CGHAP grants, rental property deductions, ACB adjustments, principal residence exemption interactions, Class 43.1 eligibility, and Quebec provincial tax obligations is essential before you apply.

RS

Rotfleisch & Samulovitch P.C.

When Can Your Crypto Losses Become Tax Deductions? A Canadian Tax Lawyer On Capital Losses vs Business Losses

Crypto losses are not all deductible in the same way. In Canada, the core question is not simply whether a taxpayer lost money on Bitcoin, Ether, Tao or another token.

RS

Rotfleisch & Samulovitch P.C.

King Charles Taxation And Canadian Comparisons: Voluntary Compliance, Crown Privilege, And Tax Transparency

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

How CRA Treats Cryptocurrency Tax In Divorce And Family Law Settlements In Canada

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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Inheritance Tax

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

Cryptocurrency has become a significant source of wealth for many Canadians. Whether an individual holds Bitcoin as a long-term investment, actively trades digital assets, participates in staking programs, or engages in decentralized finance (DeFi), cryptocurrency can create unique estate planning challenges that do not arise with traditional investments.

RS

Rotfleisch & Samulovitch P.C.

The Application Of Alternative Minimum Tax In The Year Of Death

The Federal alternative minimum tax (“AMT”) regime is intended to ensure that individuals, including certain trusts, pay a certain minimum level of tax where income tax calculated under the regular rules is reduced...

GR

Gardiner Roberts LLP

Post-Mortem Planning Just Got A Little Bit Easier: Amendments To 164(6) Loss Carryback

Recent amendments to Canada's Income Tax Act have extended the post-mortem loss carryback election from one to three taxation years, providing estate administrators significantly more time to implement tax planning strategies.

GR

Gardiner Roberts LLP

Canada-US Estate Planning: A Complete Guide For Snowbirds And Cross-Border Families

A

Altro LLP

Noël c. Birk : comment la fiscalité influence le partage d'un FERR

MT

Miller Thomson LLP

Acheter une résidence de vacances aux États-Unis : un Canadien devrait‑il utiliser une fiducie ?

MT

Miller Thomson LLP

Looking To Make 2026 Your Last Year Of Filing US Taxes? Start Your Renunciation Journey Today.

MP

Moodys Private Client Law LLP

Foreign Beneficiaries And Foreign Estate Taxes: With Globalization Comes Complexity

OE

O'Sullivan Estate Lawyers LLP

U.S. Estate Tax Planning For Canadians Under The One Big Beautiful Bill Act

A

Altro LLP

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Tax Authorities

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

The Supreme Court of Canada’s decision in Stewart v Canada, 2002 SCC 46, represents a foundational shift in Canadian tax law concerning what constitutes a “source of income” under the Income Tax Act.

RS

Rotfleisch & Samulovitch P.C.

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

The creator economy has fundamentally changed how Canadians earn income. YouTubers, Instagram influencers, TikTok personalities, Twitch streamers, podcasters, affiliate marketers, bloggers, online educators, subscription-based performers, and other digital entrepreneurs now generate substantial revenues through online platforms.

RS

Rotfleisch & Samulovitch P.C.

When Can Your Crypto Losses Become Tax Deductions? A Canadian Tax Lawyer On Capital Losses vs Business Losses

Crypto losses are not all deductible in the same way. In Canada, the core question is not simply whether a taxpayer lost money on Bitcoin, Ether, Tao or another token.

RS

Rotfleisch & Samulovitch P.C.

Legislative Update Report No. 2026-13

Canada Government

OH

Osler, Hoskin & Harcourt LLP

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

RS

Rotfleisch & Samulovitch P.C.

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)

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

See more

Property Taxes

Toronto’s Vacant Home Tax: A Complete Guide To Tax Exemptions, Tax Appeals, And Tax Compliance For Toronto Property Owners

Toronto property owners face a significant and growing municipal tax obligation that has caught many off guard — the Vacant Home Tax, commonly referred to as the VHT.

RS

Rotfleisch & Samulovitch P.C.

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)

Section 160 of the Income Tax Act (ITA) is one of the most potent collection tools available to the Canada Revenue Agency (CRA). While most tax liabilities are personal to the individual who earned the income, section 160 creates a form of “derivative” or secondary liability.

RS

Rotfleisch & Samulovitch P.C.

Ambiguous HST Clauses In Real Estate Transactions: When “Tax Included” Means Risk Assumed

Real property owners in Canada should be aware that their tax obligations may differ depending on whether a property is used for residential (such as renting as a home or apartment) or for commercial purposes (such as renting for business use).

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

Vacant Home Tax 2026 Update: Exemptions, Appeals, Deadlines, Audits, And How To Challenge A Vacant Home Tax Assessment

RS

Rotfleisch & Samulovitch P.C.

I Am A Beneficiary Of BC Real Property – What Taxes Should I Seek Advice On?

AH

Alexander Holburn Beaudin + Lang LLP

When Does Real Property Become Inventory: Capital Gains vs. Business Income In 555 Avenue Inc. v. The King

RS

Rotfleisch & Samulovitch P.C.

Règles De Revente Précipitée Et Transferts D’immeubles En Vertu De L’article 85 LIR : Une Flexibilité Bienvenue Pour Les Réorganisations Internes

MT

Miller Thomson LLP

Municipal Property Tax Appeals In Saskatchewan: Lessons From Pratchler (2026 SKMB 17)

ML

McKercher LLP

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Latest Videos

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Negotiating Tax Treaties In The Digital Age: A Conversation With David Rosenbloom (Podcast)

TL

Torys LLP

BTC Series: A Tip For Tax Season (Video)

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Watson Goepel LLP

Tax Litigation Video Series - Explaining Director Liability

AB

Aird & Berlis LLP

2024 Budget Changes: Real Estate, Home Taxes And Rentals

FH

FH&P Lawyers

Leafs' Leader, Tavares, Challenges CRA Over Tax Dispute (Video)

RA

Rosen & Associates

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