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  • Article

    Canadian Crypto Tax Lawyer's Review Of The Terra Collapse And Do Kwon's Guilty Plea

    The 2022 collapse of TerraUSD (UST) and Luna erased nearly $60 billion in global value and remains one of the most disruptive failures in cryptocurrency history.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canadian Shopify Sellers: Get Ready For The Arrival Of The Canada Revenue Agency

    If Canadian e-commerce businesses have been utilizing Shopify, the Canada Revenue Agency is interested in finding out if they have been correctly reporting their sales.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canadian Tax Consequences Of A Foreign Life Insurance Policy: CRA's Form T1135 And Reporting Requirements – Canadian Tax Lawyer Explains What You Need To Do

    All Canadian resident taxpayers must file Form T1135 if, at any point during the year, they owned specified foreign property (SFP) with a total cost of more than $100,000 CAD—even if some or all of the property was sold before year-end.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Case Commentary: Onischuk v. The King – Tax Court Rules Cannot Override CRA's Statutory Requirements

    In February 2025, the Tax Court of Canada delivered the ruling on Onischuk v. The King, 2025 TCC 17 (Onischuk). Onischuk was assessed for nil tax owing for the 2011-2012 tax years and received a refund of $627 for the 2013 tax year.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Common Reporting Standard Is Now Fully In Effect – If You Have Been Hiding Funds Or Assets Offshore, Now Is The Time To Disclose

    Gone are the days when offshore bank accounts were outside the CRA's reach. With the advent of the CRS, CRA automatically receives financial information of Canadian taxpayers who own bank accounts or assets in other jurisdictions.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Convention Expenses

    While Canadian tax law doesn't sharply define what constitutes a capital expense, it roughly characterizes a capital expense as one that "brings into existence an asset of enduring value."
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    CRA's Ex Parte Jeopardy Order Application Must Provide Full And Frank Disclosure: Guidance From A Canadian Tax Lawyer

    Jeopardy orders authorize the Canada Revenue Agency (CRA) to initiate immediate collection actions, bypassing the collections limitations outlined in the Income Tax Act.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Elections (III) Transfer Of Property Between Spouses – Mechanics Of Attribution Rules

    This article is part three of the five parts "Election Series". In this piece, the attribution rules that apply to inter-vivos transfer of property between spouses and the resulting tax consequences are discussed.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Equity, Deadline And When CRA Is At Fault – A Canadian Tax Lawyer Analysis Of Dutka v. The Queen

    As a complex and massive administrative organ, the Canada Revenue Agency ("CRA") makes its share of mistakes when it comes to processing tax returns and assessing taxpayers.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Objections And Appeals By Specified Persons – GST/HST

    If your business is subject to a GST/HST audit by the Canada Revenue Agency ("CRA") and you think the results of the tax audit are incorrect you can dispute the result.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Ontario Interactive Digital Media Tax Credit (OIDMTC) – Guidance From A Canadian Tax Lawyer

    The Ontario interactive digital media tax credit is a refundable tax credit based on qualifying expenditures incurred for eligible products and eligible digital games by a qualifying corporation during a tax year.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    RRSP Double Taxation From Overcontribution – Canadian Income Tax – Toronto Tax Lawyer Guide

    Registered retirement savings plans are a tax efficient method of investment for individuals created by the government to encourage Canadians to save for retirement.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Should A Canadian Taxpayer Seek Judicial Review? – Toronto Tax Lawyer's Analysis Of Sangha v Canada (A.G.)

    A Tax Free Savings Account (TFSA) is an investment account that allows any income earned or contributed to the account to be tax-free
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Spennie Holdings Inc. v. AGC: Tax Court Is Exclusive Forum For Tax Reassessment Disputes, Not Judicial Review Process

    The Federal Court's recent decision in Spennie Holdings Inc. et al v. Attorney General of Canada (T-1197-25, released August 15, 2025) reaffirms established Canadian tax law.
    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

    What Are The CRA Tax Breaks For Canadian Caregivers? Disability Tax Credit (DTC), Medical Expense Tax Credit (METC), And The Canada Caregiver Credit (CCC)

    Caring for a loved one with a disability or chronic illness is often a labour of love, but it often comes with significant financial strain on top of the emotional burden.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    When Are Food Expenses, Meal Expenses Deductible In Canada? Reasonable Expenses When Travelling Is Required For Work, Says Canadian Tax Lawyer

    The Income Tax Act and case law allow for various deductions for employees and businesses. Many of these deductions relate to costs incurred to produce income.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    When Is An Accountant's Work Privileged In Canada: Protecting Accountants' Work In Tax Matters, Including Litigation

    The British Columbia Supreme Court decision in Lewis v. WestJet Airlines Ltd. (2025 BCSC 1565) clarifies the circumstances under which accountants' work may be protected by legal privilege.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Why Solicitor-Client Privilege Only Applies To Tax Lawyers, Not Accountants

    Mossack Fonseca, the law firm involved in the Panama Papers scandal, was closed, but the scandal's impact on the legal profession endures.
    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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