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  • Article

    Can't Pay Your Taxes? A Primer On When CRA Grants Taxpayer Relief (TPR) On Penalties, Interest

    When a taxpayer cannot meet tax payment deadlines or fulfill other obligations set by the Canada Revenue Agency due to personal misfortune or uncontrollable circumstances, penalties and interest are typically imposed by the CRA.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canada Revenue Agency Expands Eligibility For The Claiming Of ITCs By Holding Companies – Canadian Tax Lawyer Analysis

    When a taxpayer carries on a commercial activity it inevitably incurs the additional expense of GST/HST payable on its supplies.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Emigrating With Stock Options – Canadian Income Tax – Toronto Tax Lawyer Guide

    Most forms of remuneration for employment are taxed as income in the year they are received by that employee.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    GST/HST And Invoices Of Accommodation/Convenience Schemes: Canadian Tax Lawyer Analysis

    Input Tax Credits (ITCs) are the sum of the Goods and Services Tax/Harmonized Sales Tax (GST/HST) that a registrant paid on legitimate and reasonable business expenses.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    John Wall- Federal Court Of Appeal Clarifies The Applicability Of The Principal Residence Exemption To Home Developers – A Canadian Tax Lawyer's Guide

    Arguably, one of the biggest tax breaks in the Canadian Income Tax Act is found in paragraph 40(2)(b): the principal residence exemption.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    NRST PR Rebate

    In this context the term "foreign entity" means either a foreign national or a foreign corporation.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Payroll Failure To Remit

    Canadian employers that pay salaries, wages, or most other types of remuneration to an employee are required to withhold or deduct from each wage payment made to the employee.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Scholarship, Bursaries And Fellowships Taxation: Guidance From A Canadian Tax Lawyer

    Scholarships and bursaries received toward elementary or secondary school educational programs are generally not taxable in Canada.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Taxpayer Relief For Canadians Affected By Wildfires - A Canadian Tax Lawyer's Analysis

    A taxpayer-relief application may prompt the CRA to waive or cancel the interest or penalties on your tax bill.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Top 2016 Year End Income Tax Planning Tips By Canadian Tax Lawyer Part 3

    In this Part 3 of our Canadian tax lawyer year end tax planning guide we discuss tax planning tips to benefit Canadian employees.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    IRS Math And Taxpayer Help Act: Helping American Taxpayers By Making Honest Tax Mistakes Easier To Fix

    The Internal Revenue Service (IRS) issues millions of math error notices each year. Historically, these notices provided limited information, creating confusion and increasing the risk of default assessments.
    United StatesTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Israel's 2025 Voluntary Disclosure Procedure: Updates And Clarifications For U.S. Taxpayers With Israeli Ties

    In August 2025, the Israeli Tax Authority (ITA) introduced a new Voluntary Disclosure Procedure (VDP), designed to allow taxpayers to report previously undisclosed income and assets.
    United StatesTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Court Rules That Gift Of Shares Of A Private Corporation To A Foundation Was Ineligible For A Charitable Tax Credit – A Canadian Tax Lawyer's Guide

    As a matter of social policy, Parliament recognizes the benefits of philanthropic donations to the community.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Thinking Of Co-Signing A Business Loan? Loan Guarantors Are ‘On The Hook' For The Business' Debt, Talk To A Canadian Tax Lawyer First

    According to the Federal Court decision in Abrametz v. The Queen, when a taxpayer makes a payment under a guarantee for a corporation's indebtedness, it is generally regarded that the taxpayer has acquired the rights of the creditor ...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    US-Canada Employee COVID-19 Guidelines: Toronto Tax Lawyer Guide

    Along with various COVID-19 relief programs introduced by the government, the CRA has announced policy changes to limit Canadian taxpayers and others experiencing unexpected changes to their taxes due to the pandemic.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canada's Withholding Tax Regime – Non-Resident Taxation

    Non tax residents of Canada are taxable in Canada to a tax on income from certain "passive" sources of income, including dividends, royalties, and most importantly rent under Part XIII...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    CRA Users Locked Out Of Their My Account: Canadian Tax Lawyer Guide

    Since February 16, 2021, some Canadians have been locked out of their CRA My Account because the CRA removed their addresses from their accounts.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Matthew Macisaac Consulting Inc. v Her Majesty The Queen – Guidance On Tax Court General Procedural Rule 58 From A Canadian Tax Lawyer

    In Matthew Macisaac Consulting Inc. v HMQ, Matthew Macisaac Consulting Inc. (the Appellant) brought a motion for determination of the following questions pursuant to section 58 of the Tax Court of Canada Rules (general procedure):
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Analysis Of Income Tax Act Subsection 40(3.1)

    Partnerships and their partners are subject to a number of unique Canadian taxation rules which may catch taxpayers off guard and cause them to incur tax penalties.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Report On The Voluntary Disclosures Program (VDP) – Canadian Tax Consultant Analysis

    The Offshore Compliance Advisory Committee issued a report in December 2016 to the Canada Revenue Agency about the Voluntary Disclosures Program.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.

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