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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.

When Relying On A Tax Preparer And Ignoring Tax-Return Red Flags Becomes Wilful Blindness: A Canadian Tax Lawyer’s Analysis Of Kane v. The King

A taxpayer who relies on a tax preparer may assume that any error in the resulting tax return is primarily the preparer’s responsibility. Canadian tax law is more demanding.

RS

Rotfleisch & Samulovitch P.C.

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.

Digging Deeper And Deducting Faster: What Canada’s Productivity Mega Deduction Means For Canadian Mineral Property Development

Canada's new Productivity Mega Deduction fundamentally transforms the economics of mine development by allowing 100% immediate deductibility of Canadian development expenses incurred after September 15, 2026. How will this permanent legislative change affect project financing, flow-through share premiums, and Canada's competitive position in attracting global mining capital?

ML

McMillan LLP

Productivity Mega Deduction: Canada Expands Immediate Expensing To Accelerate Capital Investments And Bolster Canada’s Tax Competitiveness

As part of the federal government’s efforts to encourage investment in Canada, Prime Minister Mark Carney announced the new Productivity Mega Deduction on September 15, 2026 at the inaugural Canada Investment Summit.

C

Cassels

CRA Cannot Ambush Taxpayers With A Brand-New Basis Of Re-Assessment, Not Even Foreign Accrual Property Income (FAPI)

RS

Rotfleisch & Samulovitch P.C.

Paradigm Tax Evasion Scheme: Porisky And Gould Lose Final Tax And GST Appeals

RS

Rotfleisch & Samulovitch P.C.

CRA Net Worth Audit 101: What To Know About The CRA Net Worth Audit & Net Worth Assessment In Canada

RS

Rotfleisch & Samulovitch P.C.

Can You Still Object If You Never Received A CRA Reassessment? A Canadian Tax Lawyer’s Analysis Of Estate Of Ducharme v. The King

RS

Rotfleisch & Samulovitch P.C.

HST Cannot Be Set Off Against Debts Owing

MK

Millar Kreklewetz

Advance Income Tax Ruling Requests For “major Investments” In Canada To Take Priority

GW

Gowling WLG

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

RS

Rotfleisch & Samulovitch P.C.

La Mégadéduction à la productivité du Canada : une nouvelle occasion pour le secteur minier

FF

Fasken (French)

CRA Releases New Guidance On The Direct Cost GST/HST Exemption For Charities And Public Service Bodies

C

Cassels

Mega Tax Measure, Mega Opportunity: What Businesses Should Know About Canada’s New Productivity Mega Deduction

ML

McMillan LLP

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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

When Relying On A Tax Preparer And Ignoring Tax-Return Red Flags Becomes Wilful Blindness: A Canadian Tax Lawyer’s Analysis Of Kane v. The King

RS

Rotfleisch & Samulovitch P.C.

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.

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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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.

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

John Tavares, NHL all-star and Captain of the Toronto Maple Leafs, is used to making headlines. Since signing with the Leafs in 2018, Tavares led the Leafs to their first second-round playoff appearance in nearly two decades, as well as the only recorded loss in the NHL to former Zamboni driver David Ayres in 2020.

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

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

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Property Taxes

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

If you are a Muslim homebuyer weighing a halal mortgage against a conventional one, the product that keeps you offside your faith may still put you offside the taxman in ways a conventional mortgage never would.

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

When CRA Denies New Housing Rebate Claim: Sharma v The King , 2025 TCC 145

RS

Rotfleisch & Samulovitch P.C.

How To Appeal The Toronto Vacant Home (VHT) Tax: Here’s What One Landlord Did To Fight VHT Assessment

RS

Rotfleisch & Samulovitch P.C.

Manitoba Expands Land Transfer Tax Regime To Capture Transfers Of Beneficial Interests In Land

MA

MLT Aikins LLP

Industrial Property Tax Reassessment: The Hidden Risk Facing Ontario Manufacturers

LL

Lerners LLP

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

RS

Rotfleisch & Samulovitch P.C.

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Income Tax

When Relying On A Tax Preparer And Ignoring Tax-Return Red Flags Becomes Wilful Blindness: A Canadian Tax Lawyer’s Analysis Of Kane v. The King

A taxpayer who relies on a tax preparer may assume that any error in the resulting tax return is primarily the preparer’s responsibility. Canadian tax law is more demanding.

RS

Rotfleisch & Samulovitch P.C.

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.

CRA Cannot Ambush Taxpayers With A Brand-New Basis Of Re-Assessment, Not Even Foreign Accrual Property Income (FAPI)

The Tax Court strikes the CRA’s attempt to plead a foreign accrual property income theory that was never part of the original tax reassessment, reaffirming firm limits on what subsection 152(9) permits.

RS

Rotfleisch & Samulovitch P.C.

Paradigm Tax Evasion Scheme: Porisky And Gould Lose Final Tax And GST Appeals

RS

Rotfleisch & Samulovitch P.C.

CRA Net Worth Audit 101: What To Know About The CRA Net Worth Audit & Net Worth Assessment In Canada

RS

Rotfleisch & Samulovitch P.C.

Can You Still Object If You Never Received A CRA Reassessment? A Canadian Tax Lawyer’s Analysis Of Estate Of Ducharme v. The King

RS

Rotfleisch & Samulovitch P.C.

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

RS

Rotfleisch & Samulovitch P.C.

La Mégadéduction à la productivité du Canada : une nouvelle occasion pour le secteur minier

FF

Fasken (French)

Canada’s Productivity Mega Deduction: A New Opportunity For The Mining Sector

F

Fasken

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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 - What To Do After Your CRA Tax Assessment (Video)

AB

Aird & Berlis LLP

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