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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.

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

A bare trust is generally an arrangement in which the trustee holds only legal title to property and acts purely as the beneficiaries’ agent, with no independent discretion over it.

RS

Rotfleisch & Samulovitch P.C.

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

A Tel Aviv District Court sentence handed down against a veteran Israeli actor and entrepreneur is a useful lens for Canadian taxpayers who want to understand how much more exposure they face if the Canada Revenue Agency (CRA) refers their file for criminal tax evasion prosecution.

RS

Rotfleisch & Samulovitch P.C.

Bare Trusts Tax Consequences: Canadian Tax Lawyer Guidance

A bare trust is one of the most common trust arrangements in which a Canadian taxpayer can find himself or herself without realizing it, and one of the most misunderstood when it comes to reporting obligations.

RS

Rotfleisch & Samulovitch P.C.

Canada Proposes New Productivity Mega Deduction

The Canadian federal government has proposed a Productivity Mega Deduction that would allow businesses to immediately expense the full cost of eligible capital investments rather than deducting them over time. This permanent tax measure aims to reduce Canada's marginal effective tax rate on new business investment to 6.4 percent, positioning it as the lowest among G7 countries and potentially reshaping where multinational corporations choose to locate capital-intensive projects.

BL

Borden Ladner Gervais LLP

Who Can Deduct Legal Fees For A Tax Dispute In Canada? Lessons From Kruivitsky v. The King

MT

Miller Thomson LLP

Imposition : Faire des affaires au Canada 2026

MT

McCarthy Tétrault LLP

Productivity Mega Deduction

TL

Torys LLP

From Super To Mega: Canada Proposes New "Productivity Mega Deduction" To Spur Investment

BJ

Bennett Jones LLP

Canada Announces Productivity Mega Deduction

BC

Blake, Cassels & Graydon LLP

CRA Releases Updated CRS Guidance: CRS 2.0 And Other Matters

BL

Borden Ladner Gervais LLP

Canada’s Productivity Mega Deduction: Big Name, Big Opportunities For Business Aviation

ML

McMillan LLP

CRA Audit Settlements: Is That A Real Thing?

MK

Millar Kreklewetz

Canada Bets On New Tax Proposals To Generate Investment: Go Big Or Go North

M

Mintz

Understanding Canada’s new "Productivity Mega Deduction": Broad-based, immediate, and permanent expensing

GW

Gowling WLG

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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

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

Robinson v Canada: Federal Court Sets Strict Mutual Agreement Procedure (MAP) Deadline In Reassessment Deals With CRA

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

The GST/HST New Housing Rebate: A Complete Guide To Eligibility, Amounts, And How To Avoid Case Law Traps

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

No GST/HST New Housing Rebate Where A Bare Trusee Takes Title

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

Sales Taxes: VAT, GST

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

Free tokens are rarely free of tax consequences. Airdrops, staking rewards, yield-farming distributions and DAO compensation all arrive in a crypto wallet without a purchase, which makes them easy to overlook at filing time, and difficult to characterize when they are not overlooked.

RS

Rotfleisch & Samulovitch P.C.

The GST/HST New Housing Rebate: A Complete Guide To Eligibility, Amounts, And How To Avoid Case Law Traps

The GST/HST New Housing Rebate lets a purchaser recover part of the GST/HST paid on a newly built or substantially renovated home used as a primary residence.

RS

Rotfleisch & Samulovitch P.C.

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

When the Canada Revenue Agency (CRA) concludes that a GST/HST registrant’s books and records do not provide a complete or reliable picture of its taxable sales, it may reconstruct those sales using an alternative or indirect audit method.

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

No GST/HST New Housing Rebate Where A Bare Trusee Takes Title

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

Bare Trusts Tax Consequences: Canadian Tax Lawyer Guidance

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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Withholding Tax

Director’s Liability For Taxes: A Canadian Tax Lawyer’s Guide To CRA Rules

Corporations are treated as distinct legal persons, separate from their shareholders, directors, and officers.

RS

Rotfleisch & Samulovitch P.C.

Imposition : Faire des affaires au Canada 2026

Ce chapitre fait partie de notre guide Faire des affaires au Canada, qui vise à aider les investisseurs internationaux à mieux comprendre les considérations juridiques, réglementaires et stratégiques qui influent...

MT

McCarthy Tétrault LLP

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

Canada’s Foreign Influence Transparency and Accountability Act came into force on August 4, 2026, creating a public registry overseen by the Office of the Foreign Influence Commissioner.

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

The End Of Regulation 105 Administrative Relief: Required Withholding From Amounts Paid To Non-residents Providing Services In Canada

MA

MLT Aikins LLP

A Canadian Tax Lawyer’s Guide To Canada’s 2026 Proposed Hybrid Mismatch Rules: What Multinational Enterprises And Cross-Border Investors Need To Know

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

Crédit privé au Canada : Principales considérations juridiques et structurelles pour les prêteurs américains

BC

Blake, Cassels & Graydon LLP

Withholding Tax And Beneficial Ownership: Insights From A Canadian Tax Lawyer On C&W Offshore Ltd. v. HMK, 2026 TCC 40

RS

Rotfleisch & Samulovitch P.C.

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Capital Gains Tax

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

A transfer generally qualifies as a gift for Canadian income tax purposes where a person voluntarily transfers property he or she owns without receiving or expecting a disqualifying benefit or consideration in return.

RS

Rotfleisch & Samulovitch P.C.

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

Free tokens are rarely free of tax consequences. Airdrops, staking rewards, yield-farming distributions and DAO compensation all arrive in a crypto wallet without a purchase, which makes them easy to overlook at filing time, and difficult to characterize when they are not overlooked.

RS

Rotfleisch & Samulovitch P.C.

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

Canada does not generally impose a separate inheritance tax on beneficiaries. That does not mean death is tax-free. Under subsection 70(5) of the Income Tax Act, a Canadian taxpayer is generally deemed to dispose of each capital property at fair market value immediately before death, unless a specific rollover or other relieving rule applies.

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

Donating Appreciated Publicly Traded Securities To Charity

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

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Corporate Tax

Who Can Deduct Legal Fees For A Tax Dispute In Canada? Lessons From Kruivitsky v. The King

The Tax Court of Canada's decision in Kruivitsky v. The King addresses whether taxpayers can claim deductions for legal fees paid on behalf of relatives in tax disputes. This ruling examines the scope of subparagraph 60(o)(i) of the Income Tax Act and its implications for family-funded tax appeals.

MT

Miller Thomson LLP

Canada Proposes New Productivity Mega Deduction

The Canadian federal government has proposed a Productivity Mega Deduction that would allow businesses to immediately expense the full cost of eligible capital investments rather than deducting them over time. This permanent tax measure aims to reduce Canada's marginal effective tax rate on new business investment to 6.4 percent, positioning it as the lowest among G7 countries and potentially reshaping where multinational corporations choose to locate capital-intensive projects.

BL

Borden Ladner Gervais LLP

Productivity Mega Deduction

The Government of Canada has proposed a permanent Productivity Mega Deduction that would allow immediate expensing for most depreciable property and Canadian development expenses acquired or incurred on or after September 15, 2026. This significant tax policy change aims to reduce the marginal effective tax rate on business investment from 13% to 6.4%, though certain exclusions and restrictions apply to specific asset categories.

TL

Torys LLP

From Super To Mega: Canada Proposes New "Productivity Mega Deduction" To Spur Investment

BJ

Bennett Jones LLP

Canada Announces Productivity Mega Deduction

BC

Blake, Cassels & Graydon LLP

Canada’s Productivity Mega Deduction: Big Name, Big Opportunities For Business Aviation

ML

McMillan LLP

Canada Bets On New Tax Proposals To Generate Investment: Go Big Or Go North

M

Mintz

Understanding Canada’s new "Productivity Mega Deduction": Broad-based, immediate, and permanent expensing

GW

Gowling WLG

CRA To Prioritize Advance Ruling Requests For Large Investments

OH

Osler, Hoskin & Harcourt LLP

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Latest Videos

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

RS

Rotfleisch & Samulovitch P.C.

First-Time Home Buyer GST Rebate For New Homes In Ontario (Video)

DS

Devry Smith Frank LLP

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

TL

Torys LLP

BTC Series: A Tip For Tax Season (Video)

WG

Watson Goepel LLP

Tax Litigation Video Series - Introduction (Video)

AB

Aird & Berlis LLP

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