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  • Article

    French Versus English Statutory Interpretation

    Justice Jorré applied the appropriate rules of statutory interpretation and determined that the French meaning must prevail.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Guide To The In-Trust-For (ITF) Account

    An In-Trust-For (ITF) account, also commonly referred to as an In-Trust Account, is an unregistered investment account commonly set up for minors in Canada.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canada Trustco Mortgage Co. v. Canada: The Supreme Court's Foundational GAAR Decision And Its Three-Step Test

    How the Supreme Court of Canada’s unified textual, contextual and purposive approach in Canada Trustco continues to govern every general anti-avoidance rule assessment issued by the CRA.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Involuntary Dispositionsfor Canadian Tax Purposes– Canadian Tax Lawyer Analysis

    The most common way for a taxpayer to dispose of a property is to voluntarily transfer the property to someone else via a sale or gift.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Scientific Research And Experimental Development Tax Credit For Medical Professionals – A Toronto Lawyer Analysis

    The Scientific Research and Experimental Development (SR & ED) Tax Credit can be a powerful tax planning tool for Canadian business owners.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    T2200 – Deducting Employment Expenses: Toronto Tax Lawyer Analysis

    While businesses and the self-employed can deduct a wide range of expenses, salaried employees are significantly more limited in their ability to deduct expenses.
    CanadaEmployment and HR
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How To Use BVI Or Other Offshore Non-CCPCs To Save Tax On Investment Income – Guidance From A Canadian Tax Lawyer

    Most Canadian small businesses operate as CCPCs (Canadian controlled private corporations) which are entitled to many tax advantages such as a lower tax rate for active business income up to $500,000 annually.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Guide To Alcohol Taxes And Duties

    Canada has some of the highest alcohol taxes in the world. Canadians pay approximately $20 billion per year in alcohol taxes and duties.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Guide To Business And Personal Tax Debt Forgiveness From CRA

    Sections 80 to 80.04 of the Income Tax Act contain the rules governing the tax consequences of debt forgiveness.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Rawlings v AGC, 2026 FC 208: Taxpayer Sought Judicial Review Of CRA's Decision To Refuse Changing His 2004 Tax Return

    When a Canadian taxpayer tried to change his 2004 tax return, CRA declined and pushed for penalties plus interest while ignoring his change request for 10 years. Judicial review sided with the taxpayer.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How CRA Views Crypto Staking On CSA-Compliant Platforms Affect Traders, Investors

    Although the first cryptocurrency, Bitcoin, was invented 17 years ago in 2008, the regulations of cryptocurrencies and crypto platforms (also known as crypto exchanges) in Canada are still in their early stages.
    CanadaTechnology
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Amendments To The Income Tax Act – Split Income Rules – Revised Legislation – A Canadian Tax Lawyer Analysis

    There has been a whirlwind of activity with respect to tax legislation during the Honourable Bill Morneau's stint as Canada's Minister of Finance.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Keith David Lawson, Another Tax Protester, Sentenced To Jail In Tax Prosecution

    Another self styled educator with the Paradigm Education Group tax protester movement has been sentenced to a jail term for tax evasion and counselling others to evade as a result of a successful tax prosecution.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How To Interpret A Tax Treaty – Guidance From A Canadian Tax Lawyer

    A tax treaty is a bilateral agreement made by two countries to resolve certain tax issues such as double taxation, pension treatment or residence status determination for tax purposes.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Guide To Ontario Foreign Homebuyer Tax

    The Ontario Foreign Homebuyer Tax is a one-time 20% province-wide tax on non-resident homebuyers. Officially named the NRST, it took effect on 30 March 2022 as a purported governmental response to the lack of housing supply ...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Perspective On Tax Court Of Canada Minutes Of Settlement vs. Consent To Judgement

    A taxpayer who proceeds to Tax Court to resolve an ongoing tax dispute will want to consider settling the dispute prior to hearing.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    B.C. Court Grants Rectification For A Corporation's Incorrectly Calculated Capital Dividend Account Balance

    The case involved 551928 Manitoba Ltd. ("the Corporation"), which hired accountants to estimate its full capital dividend account balance.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Will And Estate Planning

    Will And Estate Planning
    CanadaFamily and Matrimonial
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Builders Beware: GST/HST Now Applies On All 'Assignment Sales' (Pre-Construction Contracts) – Guidance From A Canadian Tax Lawyer

    As of May 7, 2022, changes introduced by the Federal Budget 2022 have amended Part IX of the Excise Tax Act (ETA), significantly impacting assignment sales related to newly constructed or substantially renovated single-unit residential homes and condominium units.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    GST/HST Digital Service Tax Requirements: Non-Resident Businesses

    GST/HST generally applies on the sale of goods or provision of services in Canada and is required to be collected by the vendor and remitted to the CRA.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.

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