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  • Article

    How To Navigate IRS Form W-8BEN-E For Canadian Businesses With American Suppliers

    The US has always been Canada's largest trade partner. Indeed, as of 2022, trade volume with the US alone accounts for two third of Canada's worldwide volume and is about five times that of the runner up, the European Union.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Israel Approved A Draft Bill To Exempt Foreign Residents From Crypto Taxes While Canada Tightens Its Crypto Tax Regulations

    Israel's parliament has approved the initial reading of a draft bill proposing an exemption for foreign residents from cryptocurrency taxes, a significant move to attract foreign investment in digital assets.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Preston Family Trust II v The Queen: Guidance From A Canadian Tax Lawyer Regarding Assumptions Of Facts In Replies To A Notice Of Appeal

    In Preston Family Trust II v The Queen, the taxpayers were a trust residence in Canada (the "Preston Family Trust") and two non-resident beneficiaries of the trust, John and Monika Preston.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Process Of Passing Of Accounts – Guidance From A Canadian Tax Lawyer

    Estate trustees in Ontario have the duty to make sure all assets and money are accounted so that the beneficiaries can audit the administration of an estate.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Richard T Mccullough v His Majesty The King: The Tax Court Of Canada Allows Taxpayer's Travel Expenses Of Getting To Work Denied By The CRA

    Under section 8 of the Income Tax Act, employees can deduct certain employment expenses such as meal, travel and entertainment expenses if they meet certain conditions.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Simplified Method for Claiming Input Tax Credits (ITCs) – GST/HST – Canadian Tax Lawyer Analysis

    Certain Canadian businesses that use the regular GST/HST reporting method can use a simplified method to calculate their input tax credits.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Subsection 164(6) Tax Loss Carryback On Death – A Toronto Tax Lawyer Analysis

    One of the major considerations in estate planning for Canadian taxpayer is the deemed disposition upon death.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Implications Of Stolen Cryptocurrency Or NFT – A Toronto Tax Lawyer Analysis

    Recently a US couple was arrested for stealing $US3.6 Billion of cryptocurrency from 2016 by hacking a cryptocurrency exchange.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Treaty Residence Determination: Canadian Tax Lawyer Guide

    There are two factors that determine where a taxpayer pays taxes; where income is earned and where the taxpayer is tax resident.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    The Tax Treatment Of Work Space In The Home Expenses And COVID-19 – Canadian Tax Lawyer Analysis

    Millions of Canadians who do not usually work from home are doing so due to the ongoing COIVD-19 pandemic.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Top 2017 Year-End Income-Tax Planning Tips From Canadian Tax Lawyers—Part 2: Charitable Donations

    Charitable donations serve to improve the quality of life for many Canadians. But donating to charity can also serve to reduce your overall tax burden.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    CRA's Increasing Use Of Digital Tools And AI Analytics To Enforce Penalties: What Canadian Taxpayers Need To Know Now

    The Canada Revenue Agency (CRA) is increasingly adopting advanced digital tools and artificial intelligence (AI) analytics to enhance tax compliance and enforcement.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Rectification Application: Canadian Tax Lawyer Analysis

    The applicants, Mr. Mandel and Ms. Pike, were assessed by the Canada Revenue Agency as having received shareholder benefits under subsection 15(1) of the Income Tax Act amounting to approximately $15 million each in 2019.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Rectification Application – Mandel: Canadian Tax Lawyer Analysis

    The CRA assessed the applicants on the basis that they received a taxable benefit when they were issued controlling shares in each ChildCo.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Court Of Canada Clarifies Role Of Parties' Intentions In Worker Classification

    In Insurance Institute of Ontario v. M.N.R., 2020 TCC 69, the Tax Court of Canada clarified that where a payor and a worker share a common intention regarding the nature of their relationship, that intention may prevail —
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canadian Tax Lawyer's Analysis Of Tax Collections Limitation Period

    Ms. Harrison claimed losses and other deductions in connection with her participation in two transactions in her 1988 tax return.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    CRA Super Priority For Source Deduction And GST/HST Tax Assessments — A Canadian Tax Lawyer Analysis

    The Canada Revenue Agency has a wide variety of powers at its disposal to collect tax amounts owing from taxpayers with unpaid tax assessments.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Crystallizing The Lifetime Capital Gains Exemption – A Toronto Tax Lawyer Analysis

    The lifetime capital gains exemption allows Canadian taxpayers to sell certain kinds of shares called QSBC shares as well as qualified farming and fishing properties without paying tax on the capital gains up to a set amount.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    GST/HST Director's Liability: Canadian Tax Lawyer's Guide

    Under certain provisions, a corporate director may be liable for a corporation's unremitted Goods and Services Tax/Harmonized Sales Tax (GST/HST).
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Case Comment: Baxter I.C.I. Corp. vs Attorney General Of Canada – Federal Court Will Not Reweigh Evidence In A Judicial Review Application

    In a November 13, 2025, decision, Baxter I.C.I. Corp. v. Attorney General of Canada, 2025 FC 1816, the Federal Court dismissed an application for judicial review, upholding a Canada Revenue Agency (CRA) decision ...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.

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