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  • Article

    Canadian Lawyer Analysis: Income Tax Consequences For Employee And Employer Receiving Or Paying Wages Or Salaries In Cryptocurrency

    Every person resident in Canada must pay income tax on the taxable income for each taxation year.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Subsection 55(2): The New "Purpose" Test - A Canadian Tax Lawyer's Analysis

    Taxation of inter-corporate dividends has been expanded by amendments to Subsection 55(2) of the Income Tax Act first proposed in the 2015 Federal Budget.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    The Federation Of Law Societies Of Canada Challenged The Income Tax Act Amendments Based On Charter Rights Violation

    The Federation of Law Societies of Canada has taken legal action in the BC Supreme Court, contesting the constitutionality of recent amendments to the Income Tax Act.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Voluntariness Of A Voluntary-Disclosure Application 4053893 Canada Inc – A Canadian Tax Lawyer's Guide

    The Voluntary Disclosure Program (VDP) is designed to encourage taxpayers to come forward and report incomplete, inaccurate or unreported information to the Canada Revenue Agency (CRA).
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canadian Tax Lawyer Solution To Changes To The Eligible Capital Property (Goodwill) Tax Rules – Part 2

    Having explored the concept of Eligible Capital Property along with its existing tax treatment under Canada's Income Tax Act, we will analyze the changes taking place on January 1, 2017.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Pipeline Planning: A Canadian Tax Lawyers Guide

    A "pipeline plan" or "pipeline planning" are terms expert Canadian tax planning lawyers use to identify a post-mortem tax planning technique.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Burden Of Proof For Misrepresentation In Tax Reassessments Is High—And Rests With Canada Revenue Agency (CRA)

    The Canada Revenue Agency (CRA) conducted tax reassessments for the tax years 2014, 2015, and 2016, expressing doubts about the reported amounts in taxpayer Mr. Burke's tax returns.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Case Commentary: Pyxis v. AGC – Rectification Order Does Not Replace Due Diligence, Poorly Drafted Agreements With Accountants

    In January 2025, the Ontario Court of Appeal ruled on the case of Pyxis Real Estate Equities Inc. v. Attorney General of Canada, 2025 ONCA 65, effectively overturning the decision of the Ontario Superior Court of Justice in 2024 ONSC 2039.
    CanadaLitigation, Mediation & Arbitration
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer Explains The Increased Capital Gains Tax Inclusion Rate

    On April 16th the Department of Finance released Budget 2024: Fairness for Every Generation ("Budget"). This new budget introduces a generational tax increase that affects lifelong tax planning rates for many Canadians.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Comparing The Canadian Voluntary Disclosures Program To The Moroccan Tax Amnesty Program

    Morocco's 2024 tax amnesty, enacted under the Finance Law of 2024 and concluding December 31, 2024, targeted undeclared assets and income held before January 1, 2024.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Everything Canadian Families Need To Know About The Two Types Of RESP Withdrawals: Tax-Free vs. Taxable Payments

    A Registered Education Savings Plan (RESP) is a cornerstone of educational financial planning in Canada. It allows families to save for post-secondary education through personal contributions, government grants, and tax-deferred investment growth.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How CRA Calculates Taxes When You Take Personal Trips In Your Employer's Car

    Employers often need to provide employees with vehicles to help them carry out work-related activities efficiently and conveniently. In most cases, these vehicles will also be used, to some extent, for personal activities.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How Tax Lawyers And Accountants Should Navigate Canada's New Crypto-Asset Reporting Framework

    In August 2025, the Canadian Department of Finance released draft legislation to implement the Organization for Economic Co-operation and Development's (OECD) Crypto-Asset Reporting Framework (CARF) in Canada.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How To Meet The Very High Bar For Establishing And Maintaining Canadian-Controlled Private Corporation (CCPC) Status, Plus Corporate And Tax Implications Of Share Transfer

    The classification of a corporation as a Canadian-controlled private corporation (CCPC) is one of the most significant tax designations a private enterprise can achieve.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Consequences Of A Salary Deferral Arrangement (SDA) In Canada: How It Works, Plus Exceptions

    A salary deferral arrangement is an anti-avoidance rule in Canadian tax law, designed to prevent employees from deferring tax on income that has already been earned.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Theft Of CAD$1.5 Billion Of Ethereum: How CRA Treats Stolen Property Tax-Wise; Plus, Tax Implications For Crypto Exchanges In Canada

    On February 21, 2025, Bybit, a cryptocurrency exchange, was the victim of an attack that saw 400,000 Ethereum stolen from their offline storage system. At that time, the total amount stolen amounted to roughly $1.5 billion CAD.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    When Is GST/HST Payable On Vehicle Sales? Guidance From A Canadian Tax Lawyer

    When a specified motor vehicle is acquired through a private sale (for instance, from an individual who is not registered for GST/HST purposes), the transaction is generally not subject to GST/HST.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    City Of Detroit Set To Accept Cryptocurrency For Municipal Tax Payments, Starting In 2025

    What does this mean for Canadians Paying Municipal Tax in Detroit? Will other American and Canadian Cities Follow?
    CanadaTechnology
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Illinois Announces Fall 2025 Tax Amnesty Program: What Taxpayers Need To Know

    Illinois has rolled out a major tax amnesty initiative aimed at recovering millions in delinquent state taxes. For individuals and businesses, this program offers a valuable opportunity to resolve outstanding liabilities while avoiding the heavy burden of penalties and interest.
    United StatesTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    U.S. Crypto Tax Lawyer's Review: Terra USD Collapse, Do Kwon's Guilty Plea For Fraud For $40B, And Tax Implications

    The collapse of Terra Luna in 2022 remains one of the most notorious events in cryptocurrency history. Billions in investor wealth were wiped out as the algorithmic stablecoin TerraUSD (UST) and its sister token Luna collapsed in a matter of days.
    United StatesTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.

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