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  • Article

    CRA Audits Casino Records Of Canadian Gamblers

    In a new audit approach CRA has been reviewing the records of Canadian casinos and sending proposed tax assessments amounting to multi millions of dollars to Canadian gamblers on the basis of unreported income.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Risks From Underground Banks: Toronto Tax Lawyer Analysis

    Canada has been criticized for failing to police and control the growth of underground currency exchange and banking networks in Toronto.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    ATIP Documents Via EPost Connect: Canadian Tax Lawyer Guide

    Any Canadian citizen, permanent resident, individual or corporation residing in Canada has the right to request access to records of government institutions that are subject to the Access to Information Act and the Privacy Act.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Mergers & Acquisitions - Hybrid Transaction Structure - A Canadian Tax Lawyer Analysis

    The classic question when considering an acquisition transaction is whether it will be conducted as a share sale or an asset sale.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Top 3 Canadian Income Tax Stories Of 2015

    Looking back on every year there are numerous Canadian income tax developments and changes
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Voluntary Disclosure If More Than 10 years Outstanding – Calgary Tax Lawyer Analysis

    The CRA voluntary disclosure program (VDP) only applies to the last 10 years of tax issues such as unfiled tax returns or unreported income or offshore assets not reported on a form T1135.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canada (Attorney General) v. Fairmont Hotels Inc. – SCC Update on Tax Rectification – Toronto Tax Lawyer Analysis - Part I

    Tax rectification is a remedy that can be sought when a legal document fails to reflect the tax intent of the parties to that document.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Underground Economy Tax Evasion Remains CRA Priority

    As Canadian tax lawyers we provide income tax advice to taxpayers who have engaged in unreported cash transactions and have decided to correct their back tax filings.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Commercial Rent Deferrals And Covid-19: Canadian GST/HST Lawyer Analysis

    By now, everyone is aware that the current global pandemic of Covid-19 has created complete chaos for businesses big and small.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Gordon v. Canada (Attorney General) – Taxpayer Relief– Canadian Tax Lawyer Analysis

    The Canadian Income Tax Act and Excise Tax Act leave many aspects of tax administration to the discretion of the Canada Revenue Agency (the "CRA").
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

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

    However, recent trends in the CRA's common practice have seen a general tightening of how the program is run.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Relief For Employee Remittance For Undue Hardship To Employer

    When a taxpayer fails to comply with his obligations under the Income Tax Act or other taxation statutes that the Canada Revenue Agency administers, the CRA will often apply penalties such as late-filing penalty, ...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    CRA Monitors Your Bedroom Common Law Marriage For Tax Purposes

    A common law marriage is an informal relationship that does not require the legal form of a statutory marriage.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    CRA Raids Accountants Grant Thornton – Only Canadian Tax Lawyers Have Privilege

    While there is overlap in the work that Canadian tax lawyers and tax accountants carry out on behalf of their client, the news that the Canada Revenue Agency has seized several files from a Halifax branch of Grant Thornton . . .
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Perspective On An Out Of This World Shareholder Benefit Decision – Laliberté v. Canada

    Subsection 15(1) of the Income Tax Act renders shareholder benefits taxable. A shareholder benefit arises where a shareholder receives a benefit from a corporation that is not part of a bona fide transaction ...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Perspective On Tax Clearance Certificates

    When a person passes away, he or she may leave behind unpaid tax debts.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Gifts Tax: A Canadian Tax Lawyer Analysis

    Canada does not have a gift tax in the sense that giving a gift will not immediately give rise to tax. Many gifts can be given tax-free.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Ontario's Proposed Changes In Bill 213 To The Business Corporations Act – A Canadian Tax Lawyer's Analysis

    On October 6, the Ontario government introduced Bill 213: Better for People, Smarter for Business Act, 2020 and the purpose is to make incorporation more welcoming to foreign-owned or foreign-controlled corporations.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    T5018 Statement Of Contract Payments: Toronto Tax Lawyer Analysis

    A T5018 is a CRA taxpayer information return known as the statement of contract payments.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    The Case Of Scott v Queen And The Importance Of Evidence: A Canadian Tax Lawyer's Perspective

    In the recent case of Scott v Queen 2020 TCC 4, the Tax Court of Canada released yet another decision regarding section 160 of the Income Tax Act.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.

Showing 101–120 of 1491 results

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