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Registered address: 188 Fleet Street, London, EC4A 2AG

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  • Article

    White V. The Queen

    The Canada Revenue Agency (CRA) has access to an arsenal of legal tools to ensure it can collect income tax and GST/HST from taxpayers.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Perspective On The Clergy Residence Deduction

    Members of the clergy can leverage their housing to reduce their taxes by claiming the Clergy Residence Deduction pursuant to paragraph 8(1)(c) of the Income Tax Act.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Case Commentary On Fiera Foods Company v HMK, 2023 TCC 140: Documentation For HST/GST Does Not Need To Follow Pre-Set Or Prescribed Format By CRA

    Fiera Foods Company, started in 1987, has been in the business of producing frozen bakery products for retailers in Canada and the United States.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Case Comment – Heritage Square Retirement Living Inc. v The King, 2026 TCC 39

    The taxpayer operated a personal care home in Newfoundland and Labrador and leased the building from an affiliated company. Beginning in March 2019, it paid rent to the affiliate, and the rent included GST/HST.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Section 85 Rollovers: A Canadian Tax Lawyer's Guide

    Section 85 of the Federal Income Tax Act, also known as a rollover provision, outlines the conditions required for a tax-deferred transfer of eligible property by a taxpayer to a taxable Canadian corporation.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Losses From Theft And Embezzlement Of Bitcoin & Other Assets— A Canadian Tax Lawyer Analysis

    Taxpayers, particularly those with valuable inventory or capital assets, can be crippled through the actions of opportunistic thievesand fraudsters.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Safe Income On Hand – Paying Tax Free Inter-Corporate Dividends – A Toronto Tax Lawyer Analysis

    Under Canadian tax law, corporations are able to issue dividends to certain other Canadian corporations on a tax free basis.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Integration Mechanisms: Refundable Dividend Tax On Hand (RDTOH), Aggregate Investment Income & The Part IV Tax

    RDTOH isn't simple and isn't for everybody. In fact, the dividend refund provisions in subsection 129(1) of the Income Tax Act (the "Act") only apply to a "private corporation".
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Deadlines For Notice Of Objections, Notice Of Appeals, And Extension Of Times – Canadian Tax Lawyer Explains

    Upon receiving a Notice of Assessment or Reassessment, and disagreeing with its contents, a taxpayer may choose to file a formal dispute with the Canada Revenue Agency by filing a written Notice of Objection.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Intergenerational Transfers Of Businesses After Canada's Bill C-208

    Bill C-208, An Act to amend the Income Tax Act (transfer of small business or family farm or fishing corporation), received royal assent and became law in Canada on June 22, 2021.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Litigators May Represent Corporations In Canada Tax Court Appeals

    Canada's various taxing statutes provide detailed administrative procedures for disputing reassessments including most importantly income taxes and GST/HST.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    What Is A Taxable Benefit? — A Canadian Tax Lawyer Explains

    A taxable benefit occurs anytime a taxpayer receives a monetarily measurable economic advantage or benefit.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Civil Penalties For Third-Party Tax Advisors – A Toronto Tax Lawyer Commentary On Ploughman v The Queen

    The civil penalties for tax planners and tax preparers were introduced in the 2000 budget in order to deter those who promote tax shelters.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Cross-Border Tax: How Trump's 'One Big Beautiful Bill' (OBBB) Will Affect Canadians With American Income, Investments, Business Operations

    The U.S. recently enacted the One Big Beautiful Bill (OBBB), a major tax reform affecting individuals and corporations. While primarily U.S.-focused, the legislation has important consequences for Canadians with U.S. income, investments, or business operations.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Closing The Loophole On Indirect Trust Transfers And The 21-Year Deemed Disposition Rule: New Measure In Budget 2025

    For Canadian tax planners and trust beneficiaries, the “21-year rule” is a critical milestone.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Condo Flipping: A Canadian Tax Lawyer's Perspective

    In recent years, the Canada Revenue Agency (the "CRA") has become more critical of real estate transactions claiming tax non-compliance has contributed to increasing housing prices.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Central Springs Limited – Limitations On CRA Collections Abilities

    The Canada Revenue Agency has been granted extensive powers under the Canadian Income Tax act to help them collect tax arrears.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Charging GST/HST: A Single Supply vs Multiple Supplies – Canadian Tax Lawyer Explains The Difference

    If you sell goods or provide services in Canada, you likely need to register for and charge customers the Goods and Services Tax or the Harmonized Sales Tax, unless your business has a low sales volume or qualifies for an exception.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Vefghi Holding Corp. v. Canada: How To Avoid The "Tax Trap" On Timing Of Flow-Through For Dividend Income And Timing Of Receipts For Trusts

    For Canadian tax planners and business owners, utilizing inter vivos trusts to flow income through from corporations to beneficiaries is a common strategy for tax deferral and to multiply access to the lifetime capital gains exemption.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    SECURE 2.0: Key Provisions And Tax Planning Implications For American Retirees

    SECURE 2.0 strengthens the U.S. retirement system by expanding contribution opportunities, increasing flexibility for savers, and imposing new compliance obligations.
    United StatesTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.

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