ArticleFrench Versus English Statutory InterpretationJustice Jorré applied the appropriate rules of statutory interpretation and determined that the French meaning must prevail. CanadaTaxRotfleisch & Samulovitch P.C.
ArticleA Canadian Tax Lawyer's Guide To The In-Trust-For (ITF) AccountAn 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.CanadaTaxRotfleisch & Samulovitch P.C.
ArticleCanada Trustco Mortgage Co. v. Canada: The Supreme Court's Foundational GAAR Decision And Its Three-Step TestHow 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.CanadaTaxRotfleisch & Samulovitch P.C.
ArticleInvoluntary Dispositionsfor Canadian Tax Purposes– Canadian Tax Lawyer AnalysisThe 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.CanadaTaxRotfleisch & Samulovitch P.C.
ArticleScientific Research And Experimental Development Tax Credit For Medical Professionals – A Toronto Lawyer AnalysisThe Scientific Research and Experimental Development (SR & ED) Tax Credit can be a powerful tax planning tool for Canadian business owners.CanadaTaxRotfleisch & Samulovitch P.C.
ArticleT2200 – Deducting Employment Expenses: Toronto Tax Lawyer AnalysisWhile 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 HRRotfleisch & Samulovitch P.C.
ArticleHow To Use BVI Or Other Offshore Non-CCPCs To Save Tax On Investment Income – Guidance From A Canadian Tax LawyerMost 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. CanadaTaxRotfleisch & Samulovitch P.C.
ArticleA Canadian Tax Lawyer's Guide To Alcohol Taxes And DutiesCanada has some of the highest alcohol taxes in the world. Canadians pay approximately $20 billion per year in alcohol taxes and duties. CanadaTaxRotfleisch & Samulovitch P.C.
ArticleA Canadian Tax Lawyer's Guide To Business And Personal Tax Debt Forgiveness From CRASections 80 to 80.04 of the Income Tax Act contain the rules governing the tax consequences of debt forgiveness.CanadaTaxRotfleisch & Samulovitch P.C.
ArticleRawlings v AGC, 2026 FC 208: Taxpayer Sought Judicial Review Of CRA's Decision To Refuse Changing His 2004 Tax ReturnWhen 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.CanadaTaxRotfleisch & Samulovitch P.C.
ArticleHow CRA Views Crypto Staking On CSA-Compliant Platforms Affect Traders, InvestorsAlthough 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. CanadaTechnologyRotfleisch & Samulovitch P.C.
ArticleAmendments To The Income Tax Act – Split Income Rules – Revised Legislation – A Canadian Tax Lawyer AnalysisThere has been a whirlwind of activity with respect to tax legislation during the Honourable Bill Morneau's stint as Canada's Minister of Finance.CanadaTaxRotfleisch & Samulovitch P.C.
ArticleKeith David Lawson, Another Tax Protester, Sentenced To Jail In Tax ProsecutionAnother 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.CanadaTaxRotfleisch & Samulovitch P.C.
ArticleHow To Interpret A Tax Treaty – Guidance From A Canadian Tax LawyerA 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. CanadaTaxRotfleisch & Samulovitch P.C.
ArticleA Canadian Tax Lawyer's Guide To Ontario Foreign Homebuyer TaxThe 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 ...CanadaTaxRotfleisch & Samulovitch P.C.
ArticleA Canadian Tax Lawyer's Perspective On Tax Court Of Canada Minutes Of Settlement vs. Consent To JudgementA taxpayer who proceeds to Tax Court to resolve an ongoing tax dispute will want to consider settling the dispute prior to hearing. CanadaTaxRotfleisch & Samulovitch P.C.
ArticleB.C. Court Grants Rectification For A Corporation's Incorrectly Calculated Capital Dividend Account BalanceThe case involved 551928 Manitoba Ltd. ("the Corporation"), which hired accountants to estimate its full capital dividend account balance.CanadaTaxRotfleisch & Samulovitch P.C.
ArticleWill And Estate PlanningWill And Estate Planning CanadaFamily and MatrimonialRotfleisch & Samulovitch P.C.
ArticleBuilders Beware: GST/HST Now Applies On All 'Assignment Sales' (Pre-Construction Contracts) – Guidance From A Canadian Tax LawyerAs 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.CanadaTaxRotfleisch & Samulovitch P.C.
ArticleGST/HST Digital Service Tax Requirements: Non-Resident BusinessesGST/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. CanadaTaxRotfleisch & Samulovitch P.C.