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  • Article

    Taxation For Non-Profit Organizations: Canadian Tax Lawyer's Guide

    What constitutes a non-profit organization for tax purposes is defined in paragraph 149(1)(l) of the Income Tax Act.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Federal Court Granted CRA Access To Big Box Store's Client Lists That May Uncover Tax Fraud And Evasion: Guidance From A Canadian Tax Lawyer On CRA's Power To Compel Third Parties To Disclose Information

    In November 2022, the Federal Court granted the CRA's request to force J.D.Irving to turn over its clients' data from January 1, 2019, which included the complete name, contact information, CRA business number or social insurance number and ...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Guide To Section 85 Late Filed Election

    A transfer of property is a taxable disposition and generally triggers a deeming rule that the transferee has received the property at its fair market value under subsection 69(1) of the Income Tax Act.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Toronto Tax Lawyer's Guide To Basic Personal Amount Tax Credit

    The Basic Personal Amount (BPA) is a non-refundable tax credit that can be claimed by all individuals who are Canadian tax residents.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canada's Auditor General Slams The Canada Revenue Agency For Unfair Treatment Of Taxpayers

    On September 18, 2018, the Auditor General of Canada released its audit report on the Canada Revenue Agency's tax compliance efforts.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canada Revenue Agency (CRA's) Administration Of Proposed Capital Gains Taxation Changes: An Update

    Legal challenges against the Canada Revenue Agency (CRA) escalated in January 2025 with two separate lawsuits questioning its authority to enforce the federal government's proposed capital gains tax increase.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canada v. Chriss – Directors Tax Liability Defences – Toronto Tax Lawyer Case Comment

    Under Canadian tax law, the directors of corporations can be held personally liable for the unpaid GST/HST or payroll remittances of their corporation.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Case Commentary: Fijal V. The King, 2024 TCC 116 – Why Proper Bookkeeping Is The Best Protection For Businesses When They're Reassessed By The CRA

    In September 2024, the Tax Court of Canada delivered its judgment on Fijal v. The King, 2024 TCC 116.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    CRA Tax Benefits For Canadian Caregivers: Disability Tax Credit (DTC), Medical Expense Tax Credit (METC), And Canada Caregiver Credit (CCC)

    Caring for a loved one with a disability or chronic illness is an act of compassion, but it often brings significant financial challenges along with the emotional toll.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How Canadian Crypto Traders And Investors Should Handle Losses On Obsolete Crypto Inventory On Their Taxes

    In April 2025, the CRA issued an interpretation on losses on obsolete crypto inventory. The interpretation provides an official position of the CRA on the treatment of crypto assets that were purchased by the taxpayer to sell for profit and that have become worthless.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How Canadian Taxpayers Should Handle Gain Or Loss From Disposition Of NFTs: Unfortunately, Most NFTs Are Worthless; A High Percentage Of NFTs Have Almost Zero Capital Value

    According to a recent report from dappGambl, based on data provided by NFTs Scan and CoinMarketCap, it was revealed that out of the 73,257 NFT collections examined by the researchers, a staggering 95% of them...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How The Canadian Taxation System Works Part II: A Canadian Tax Lawyer Explains Benefits, Taxes, And Credits To Tech Worker Immigrants, Newcomers

    On June 27, 2023, IRCC launches Canada's first-ever Tech Talent Strategy, announcing aggressive attractions measures, including allowing H-1B visa holders in the United States to apply for a 3-year Canadian work permit...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How To Properly Claim Employment Insurance Repayments And Protect Your Tax Relief: Lessons From Dandees v. The King (2025 TCC 171)

    In Dandees v. The King, 2025 TCC 171, the Tax Court of Canada addressed a common but often misunderstood issue in income tax disputes: when Employment Insurance benefits are repaid later, can a taxpayer choose the year to claim the repayment deduction for a better tax outcome?
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    In Both Canada And The U.S.A., Sales Of Non-fungible Tokens (NFTs) Are Taxable And Must Be Reported To CRA, IRS, Respectively, Says Canadian Crypto Tax Lawyer

    In April 2025, Waylon Wilcox, 45, from Pennsylvania pleaded guilty in the U.S. federal court to two counts of falsified tax returns, concealing millions of dollars in income from non-fungible token (NFT) sales.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Income From Illegal Activities Still Taxable: CRA Targeting Cryptocurrency Transactions Likely Used For Money Laundering, Theft, Fraud, Drugs, Guns, Human Trafficking, Terrorism

    According to the Financial Transactions and Reports Analysis Centre of Canada (Fintrac), criminals are expected to continue using cryptocurrency to hide their assets from traditional banking systems.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Israel Introduces New Options For The Voluntary Disclosure Application; Canadian Voluntary Disclosure Program Remains Unchanged

    The Israeli Voluntary Disclosure Procedure Removes the Anonymous Track but Introduces a Fast-track Option for Unreported Cryptocurrency Assets.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    IRS Reverses Course On DeFi Broker Rule: Impact On U.S. Crypto Investors And DeFi Platforms

    The U.S. cryptocurrency sector continues to evolve as regulators clarify crypto tax obligations.
    United StatesTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Three Recent U.S. Tax Evasion Prosecutions: Bitcoin, Payroll Taxes, And Yoga Empire

    Recent IRS tax evasion prosecutions reflect how diverse misconduct—from sophisticated crypto concealment to failure to remit payroll taxes and repeated non-filing—can result in serious legal consequences.
    United StatesTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Top 5 Individual Tax Changes In The New US Tax Bill (2025 Update)

    The recently passed federal tax bill represents one of the most significant overhauls of the US tax code in recent years. For individual taxpayers, the legislation introduces several measures designed to adjust tax burdens, incentivize savings, and modernize compliance rules.
    United StatesTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Federal Court Of Appeal Strikes Down CCPC Continuance Planning Under GAAR In Canada V. DAC Investment Holdings Inc: Guidance From Canadian Tax Lawyer

    On February 20, 2026, the Federal Court of Appeal (FCA) released its decision in Canada v. DAC Investment Holdings Inc. (DAC), 2026 FCA 35, overturning the Tax Court of Canada’s (TCC) ruling that a corporate continuance used to exit the Canadian-controlled private corporation (CCPC) regime did not amount to abusive tax avoidance.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.

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