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  • Article

    Retroactive GST/HST Registration

    In 1991 parliament passed amendments to the Excise Tax Act to create the Goods and Services Tax ("GST").
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Toronto Tax Lawyer Guidance On Employee Legal Expenses Deduction

    In some circumstances, taxpayers earning income from employment may be able to deduct employment related expenses from their income to reduce the income tax they owe to the Canada Revenue Agency.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canadian Taxation Of U.S. Not Tax-Deductible: Roth IRAs And 401(K) Accounts

    Many Canadians who used to work in the US have Individual Retirement Accounts (IRAs) and qualified retirement plans, such as 401(k) plans.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Taxpayer Relief Application: Canadian Tax Litigator's Tax Guidance

    Allstaff Inc. (the "Taxpayer") is a temporary employment agency that employed its own workers and contracted them out to its clients.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    CANADIAN TAX LAWYER DISCUSSION OF DEBT FORGIVENESS: How To Utilize Gains On Settlement Of Debt, Mortgage Foreclosure & Default Sales In A Tax Efficient Manner

    Various commercial events will result in realization of income for the purposes of the Income Tax Act. Occurrences such as the settlement of a debt for less than full repayment creates an economic windfall for those receiving the debt relief.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Gifting Shares Of A Publicly Traded Company

    In the case of donated securities, the clearing date for the securities transfer to the charity has to take place by December 31.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Taxation Of Cryptocurrency Stablecoins – Guidance From A Canadian Tax Lawyer

    The cryptocurrency market has been highly volatile for the past several years. In fact, it is one of the most volatile non-derivative financial assets on the market.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    When Are Canadian Expats Exempt From Withholding Tax From Employment Income? Under These Specific Circumstances

    Canadian tax residents are taxed based on their worldwide income. However, non-residents for Canadian tax purposes (which is a different test then immigration purposes) are only liable for Canadian tax on their Canadian source income ...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Case Commentary: Glencore v. Canada – How Are Commitment Fees And Break Fees In M&A Transactions Taxed? Windfall Or Business Income?

    In March 2024, the Supreme Court of Canada denied the application for leave to appeal by Glencore Canada Corporation, the taxpayer, against the CRA, finally closing a tax dispute that had been dragging on for almost 30 years.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How To Claim A Tax Loss & Tax Deductions For Victims Of 'Pig Butchering' Fake Crypto Investment Scams Tip: Tips From A Canadian Tax Lawyer

    A pig butchering scam is a fraud in which people are convinced to invest money in cryptocurrency into a fake crypto trading platform that seemingly generates very high returns.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    New Trust Tax Reporting Rules: Toronto Tax Lawyer Analysis

    Draft legislation on tax reporting rules for trusts was initially proposed in July of 2018 and later confirmed in the Federal Government's 2019 Budget.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Real Estate Taxation For Canadian Non-Resident Owners

    In the previous article found here, we discussed the various tax considerations that apply to non-residents of Canada when acquiring Canadian real estate.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    The Canadian Taxation Implications For Individual Non-Residents Disposing Of Canadian Real Property- Tax Guide By Canadian Tax Lawyer

    The Canadian tax laws addressing the tax of individual non-residents disposing of Canadian real property are, although not drastically different from those imposed in similar transactions...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canada Revenue Agency Claws Back $458 Million In CEWs Wage Subsidies From COVID-19 Pandemic Following Audits

    The Canada Revenue Agency (CRA) has revealed that $458 million in funds distributed to employers through a pandemic-era wage subsidy program have either been denied or adjusted.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    When Can The CRA Advance An Alternative Argument? A Toronto Tax Lawyer Analysis Of Subsection 152(9) Of The Income Tax Act

    During a typical tax dispute between a taxpayer and the CRA, the CRA will advance one or several grounds for the assessment or reassessment against a taxpayer.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canadian Tax Lawyer Strategy For Addressing Changes To The Eligible Capital Property (Goodwill) Tax Rules - Part 3

    In this final part of the article, we explain how SME business owners who move quickly can secure preferential tax treatment for their Eligible Capital Property (goodwill).
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canada Revenue Agency (CRA) Requires Written Indication To Claim Input Tax Credits (ITCs) On Rebates From Manufacturers, Distributors

    Many distributors and manufacturers provide their customers or third-party purchasers rebates on their products or services.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    MNR v Zhao – Guidance From A Canadian Tax Lawyer On The Canada Revenue Agency's Collection Action When There Are Reasonable Grounds For Delay

    In MNR v Zhao, the Canada Revenue Agency (CRA) filed an ex parte application for a jeopardy order authorizing CRA to take collection action with respect to amounts of income tax owing that were assessed against a taxpayer.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    The Court Of Canada Rules That Post-Doctoral Fellows Are Not Employees Of The University In The University Of New Brunswick V. The Minister Of National Revenue

    In The University of New Brunswick v. The Minister of National Revenue, 2023 TCC 72, the University of New Brunswick, appealed a decision of the CRA, that classified a post-doctoral fellow as an employee of the University.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Altcoin Purchases On Ontario-Based Crypto Exchanges Are Now Subject To An Annual Limit Of $30,000 CAD

    Bitbuy and Newton, two cryptocurrency exchanges based in Canada, have implemented a yearly purchase limit of $30,000 Canadian for "restricted coins" for their users residing in Ontario.
    CanadaTechnology
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.

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