The next step in this saga for the Samaroos would be to seek leave of this decision to the Supreme Court of Canada.

As part of its push to uncover unreported income, the Canada Revenue Agency ("CRA") has successfully obtained a requirement for information from the Federal Court of Canada to require PayPal...

In the recent case of SEC v. Wyly (SDNY, no. 1:10-cv-05760, 2014 BL 267268), the US Securities and Exchange Commission (SEC) successfully obtained a disgorgement order against Samuel Wyly and the estate of Charles Wyly.

Bitcoin, writes Vern Krishna, is "a multi-faceted, highly technical and difficult to trace asset that may quite possibly be a pyramid scheme."

The Canada Revenue Agency recently published a news release, in which it identifies over $1 billion in unpaid taxes in the BC and Ontario real estate sectors since 2015.

In Achim Bekesinski and Her Majesty the Queen, the taxpayer, as director of a corporation, was personally reassessed by the Minister of National Revenue.

In 1966, the Carter Commission recommended that the income tax system should consider the family (spouse and minor children) as the basic unit for determining tax liability.

The public debate on "fair taxation" has escalated since the Minister of Finance, Bill Morneau...

One of the trends that emerged in 2017 was the increased interest, curiosity, and popularity of cryptocurrencies such as Bitcoin.

Canadian residents pay income tax on their worldwide income. In an effort to crack down on unreported offshore income, the Canada Revenue Agency (the "CRA") ...

The 600-plus-page GOP tax bill was signed by President Trump on December 22, 2017, becoming Public Law no. 115-97, commonly known as the Tax Cuts and Jobs Act or US tax reform.

Tax credits are crucial to the film and television industry, and Ontario has been a particularly attractive location for productions since the beginning of its film and television tax credit program.

Montminy ( 2016 TCC 110) is the first case to consider the interaction between regulations 6204(1)(b) and 6204(2) (c). The TCC concluded that the latter does not apply to negate the two­year...

2022 was not a good year for investors. Stocks and bonds tumbled, and bitcoin crumbled. The S&P/TSX composite index was down 8.7%; the S&P 500 lost 19.4%; NASDAQ composite...

For Canadian tax purposes, an estate is now deemed to be a trust under a 2013 amendment to the subsection 248(1) definition of a trust.

There are very few rules in tax law that protect taxpayers. Most are written to protect the Canada Revenue Agency and the government.

A professional corporation allows professionals — such as doctors, dentists, lawyers and accountants — to provide their services to clients through a corporate entity, rather than personally.

The CRA recently provided a technical interpretation where it discussed the application of the "specified corporate income" rules as proposed in the 2016 federal budget.

Tax policy should be concerned with the effectiveness and efficiency of compromises between a nation's economic, social, cultural and political values.

IRC section 267A, added December 2017, denies a deduction to a US-situated payer of interest or a royalty to a related non-US hybrid party or as part of a hybrid transaction.