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  • Article

    Federal Court Of Appeal: Aeroplan Promos To CIBC Subject To GST

    On May 20, 2021, the Federal Court of Appeal released its much-anticipated decision in CIBC v The Queen, 2021 FCA 96, upholding the ruling of the Tax Court of Canada that Aeroplan provided promotional and marketing services to CIBC subject to GST.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    GST/HST Tax Audit – Builders Of Residential Real Property And Self-Supply – A Canadian Tax Lawyer Analysis

    Building a new home, or renovating an old one, can be a stressful and overwhelming process. CRA can add to the stress by conducting a GST/HST Tax Audit.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Improvements Coming To Income Tax Notice Of Objection Process - Canadian Tax Lawyer Analysis

    In this 2 part article on the CRA review by the Auditor General of Canada our expert Canadian tax lawyers analyze the report and explain changes to the tax Notice of Objection process....
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Introduction – The Canada Revenue Agency Responds To The First Stream Of Applications Under The New Voluntary Disclosures Program (VDP)

    Yet the IC contemplates that a disclosing taxpayer may require additional time to submit the completed tax returns
    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

    Neyedly V. Attorney General Of Canada – A Canadian Tax Lawyer Analysis Of Judicial Review Of Tax Cases

    Neyedly, the applicant, sold used boats but didn't report income or expenses related to this business in 2005.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Revera Long Term Care Inc. V. Canada (National Revenue) – Misrepresentations & Errors In Reporting Income And Normal Reassessment Period

    Under the Income Tax Act, the Canada Revenue Agency ("CRA") is permitted to inspect and reassess a taxpayer's personal and or corporate tax returns for any reason.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Guidance For Assignors In A Real Estate Assignment Transaction – A Toronto Tax Lawyer Analysis

    Buying and Selling real estate assignments is a common form of transaction in the real estate market. An assignment is a transaction of the rights to a property before the legal ownership of the actual property is transferred.
    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

    The Tax Court Of Canada Tests A New Procedure – The Preliminary Ruling Docket: Canadian Tax Lawyer Analysis

    With the rise of the internet and the plethora of information available to anyone with a smartphone, there has been a marked increase in taxpayers who choose to self-represent when they appeal their assessments to the Tax Court of Canada.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Top 2016 Year End Income Tax Planning Tips By Canadian Tax Lawyer Part 5

    Part 5 of our Canadian tax lawyer year end tax planning article discusses tax planning opportunities for small business owners.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Video

    Top 2017 Year-End Income-Tax Planning Tips From Canadian Tax Lawyers—Part 3: Investments (Video)

    In Part 3 of this series, our Canadian tax lawyers provide their top year-end tax-reduction strategies concerning investments.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    What Happens To Your Registered Retirement Savings Plans (RRSPs) Upon Death? The Designation Of Beneficiaries And Subsection 51(1) Of Ontario's Succession Law Reform Act – A Canadian Tax Lawyer Tax Guide

    Registered retirement savings plans (RRSPs) are specifically designed to promote and encourage retirement savings for Canadian taxpayers.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Guidance On T1135 For Cryptocurrencies

    The T1135 is a reporting form where Canadian resident taxpayers report to the Canada Revenue Agency any specified foreign property they own if the specified foreign property has a cumulative adjusted cost base of $100,000 CAD or more.
    CanadaTechnology
    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.
  • Article

    The CRA & KPMG: Far From A Sweetheart Deal

    In my tax practice I deal with voluntary disclosure files on a daily basis and I have submitted well over a thousand such files over the years.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Withholding Tax And Beneficial Ownership: Insights From A Canadian Tax Lawyer On C&W Offshore Ltd. v. HMK, 2026 TCC 40

    The recent decision in C&W Offshore Ltd. v. HMK, 2026 TCC 40, serves as a stark reminder to Canadian businesses of the rigorous obligations imposed by Part XIII of the Income Tax Act (ITA) when dealing with non-resident suppliers.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Guide To Income Tax Act Offences And Punishment

    As the Canadian tax system is based upon taxpayers self-assessing and self-reporting their income, to protect the integrity and fairness of the system, various enforcement mechanisms are in place to ensure compliance.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How To Unwind 'Deemed Disposition' For Returning Canadian Tax Residents – Guidance From A Canadian Tax Lawyer

    When you move from Canada, you may be subject to the ‘deemed disposition' tax rules. These rules treat you as having sold certain property you own at its fair market value (FMV) on the date you cease to be a Canadian resident, causing you to realize any accrued capital gains or losses.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Proposed First Home Savings Account – Canadian Income Tax – Toronto Tax Lawyer Guide

    During the 2021 federal election, the Liberal Party of Canada proposed introducing a new form of tax favoured account: the First Home Savings Account
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.

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