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  • 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.
  • Article

    Why Taxpayers Cannot Rely On Advice From The CRA: A Canadian Tax Lawyers Perspective

    It should come as no surprise to anyone who has ever regularly dealt with the Canadian Revenue Agency ("CRA") that the CRA isn't always right when it comes to tax Law
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Implications Of QuadrigaCX Lost Cryptocurrency Keys – A Canadian Tax Lawyer Analysis

    QuadrigaCX, Canada's largest cryptocurrency exchange, lost its founder and chief executive Gerald Cotton on December 9, 2018.
    CanadaTechnology
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    2018 Federal Budget – New Trust Reporting Requirements – A Toronto Tax Lawyer Analysis

    In the 2018 Federal Budget released by the Canadian Department of Finance of February 27, 2018, new trust reporting requirements are designed to provide the CRA more information...
    CanadaCorporate/Commercial Law
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Case Comment – MNR v Roofmart Ontario Inc. ("Roofmart")

    The CRA has general powers to require persons to provide information related to a tax audit however these general powers are limited, such that, the CRA cannot require persons to provide third party documents without judicial authorization.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Extension Of Time To File Notice Of Objection To CRA Income Tax Assessment

    Subparagraph 165(1)(a)(ii) of the Tax Act only requires, in essence, that a CRA notice of assessment be sent.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    SCC Update On Tax Rectification

    Part III of this Toronto tax lawyer tax rectification article discusses the Supreme Court of Canada's decision and its tax planning implications.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Taxpayers Win Fiscal Arbitrators Gross Negligence Penalty Cases

    Four Tax Court judgements on cases involving income tax fraud as a result of false statements on Canadian tax returns were recently issued.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Thin Capitalization Rules – A Canadian Tax Lawyer Guide

    When non-Canadian residents decide to start a corporation in Canada to operate a business, an important typical question is how to fund that business.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Adventure Or Concern In The Nature Of Trade – A Canadian Tax Lawyer's Guide

    The Federal Income Tax Act ("Tax Act") outlines the sources of income that are taxable, including income from office, employment, business, and property.
    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 II

    Part I of this article provided background on the doctrine of rectification and how it is used in the Canadian tax context.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    RRSP Meltdown Strategy: A Canadian Tax Lawyer's Tax Guidance

    The Registered Retirement Savings Plans (RRSP) offer Canadians a great opportunity to defer tax in their retirement savings.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Court Of Canada's Rejection Of Solar Panel Shingles As SRED

    What constitutes SRED under the Income Tax Act, s. 248(1), will depend significantly on not only the possibility of scientific advancement, but also whether the process involved to reach the advancement involved scientific hypothesis ...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How Does A Retirement Compensation Arrangement Work And What Are The Benefits? – Tax Guidance From A Canadian Tax Lawyer

    As described in CRA publication T4041(E) Rev.20, an RCA is a plan or an arrangement under which an employer, former employer, and in some cases an employee makes contributions to a person or partnership, ...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Financial Service As An Exempt Supply From GST/HST – Guidance From A Canadian Tax Lawyer To Applewood Holdings Inc. v The Queen

    The GST/HST is a tax that applies to most supplies (sales) of goods and services made in Canada.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    PayPal CRA Court Order - When Shared Economy Becomes Underground Economy

    A tax fishing expedition is where CRA goes to a third party to obtain general third party information that may aid them in auditing taxpayers rather than the subject of the information order.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Non- Resident Carrying On Business In Canada Through Agents And Shareholders – A Canadian Tax Lawyer Analysis

    In our previous article we discussed the definition of business and analysed the tests for, and the consequences of, carrying on business in Canada.
    CanadaCorporate/Commercial Law
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Scary Taxes For Halloween

    The ghouls and ghosts of Halloween do not stop the haunting of taxation issues. Our experienced Canadian tax lawyers have chosen a few Halloween related facts and stories to delight or scare this Halloween season.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Specified Members Of Partnerships

    Partners in partnerships face different tax rules depending on the nature and amount of their involvement in the partnership.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Guidance On Valuing Inventory Explained By Canadian Tax Lawyer

    Yorkwest Plumbing Supply Inc., a Canadian-controlled private corporation that supplies plumbing equipment to contractors, decided to switch its inventory tracking system from a periodic system to a more modern perpetual system ...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.

Showing 121–140 of 1491 results

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