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  • Article

    A Canadian Tax Lawyer's Perspective On The 12-Month House Flipping Federal Budget Proposal

    On April 7th, 2022, the federal government announced its new fiscal budget proposal. Many of the proposed changes were directed towards addressing the lack of affordable housing.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Barrs v The Queen: A Canadian Tax Lawyer's Update On Taxpayer Relief Under S.220(3.1)

    Federal Court of Appeal ruled that the CRA's review officer's failure to engage with the request for equitable treatment was unreasonable.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canada's 2025 Federal Budget: Critical Changes To Cryptocurrency Taxation Investors, Traders, And Miners Need To Know

    The 2025 federal budget significantly reshapes cryptocurrency taxation in Canada, with important implications for both individuals and businesses. The measures reflect a broader federal strategy to close compliance gaps and strengthen tax administration around digital assets.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canada Recovery Hiring Program (CRHP): Toronto Tax Lawyer's Guide

    With public health measures and local economies gradually reopening, on June 2, 2021, the federal government announced the introduction of a new program—the Canada Recovery Hiring Program (CRHP)...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canada Revenue Agency Increases Efforts To Uncover Unreported Cryptocurrency & Offshore Income – A Canadian Tax Lawyer's Analysis

    In July 2018, the Canada Revenue Agency announced its progress in exposing those who evade tax by using offshore entities or cryptocurrencies such as Bitcoin, Litecoin, Ethereum, Dash, Zcash, and Ripple.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canadian Tax Lawyer Analyzes Tax Voluntary Disclosure Programs Around The World – Part III: Canada Versus The UK

    This is Part III of the series, which examines the similarities and differences between the voluntary disclosure program available in Canada and in the UK.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Case Commentary Cassidy v Canada: Using 'Extraordinary Circumstances,' CRA's Delays, Inability To Pay, Or Financial Hardship When Seeking Taxpayer Relief

    Taxpayers may, under subsection 220(3.1) of the Income Tax Act ("Tax Act"), request relief for penalties and interest in what is referred to as a taxpayer relief application (formerly known as fairness application).
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    CRA To Introduce New Automatic Tax Filing System As Many Canadians Miss Out On Benefits

    The Canada Revenue Agency (CRA) is set to pilot a new automatic tax filing system in 2024.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Elections (I) Saving Taxes: Elections Are A Great Tool

    Canadian taxpayers may be surprised to know that choice pervades the Canadian tax system. A common perception of the Canadian taxation is a complex labyrinth where a taxpayer has no choice but to follow the rules prescribed.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Everything You Need To Know About Canada's New Digital Services Tax Act

    On June 28, 2024, the Digital Services Tax Act (DSTA) entered into force. The introduction of the Digital Services Tax represents a significant shift in the country's approach to taxing the digital economy.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How To Leverage The New Tool Employer Ownership Trust For Business Ownership Planning

    An Employee Ownership Trust (EOT) is a Canadian-resident trust designed to hold shares in qualifying businesses on behalf of employees, supporting succession planning and promoting employee ownership in small and medium-sized enterprises.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    New Reporting Rules On Tax Treatment Of Severance Settlements; Update From Canadian Tax Lawyer

    The Canada Revenue Agency ("CRA") has long adhered to the Surrogatum principle, which applies the same tax treatment of settlement payments and damages awarded at trial by a judge.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Lawyer Guide To Filing Notice Of Objection And Extension Of Time Application

    Generally speaking, the starting point regarding the administration of income tax law in Canada is subsection 150(1), which states that a taxpayer must prepare and file an income tax return for each tax year ...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    What Is The EFILE Program? Eligibility, Requirements, Obligations, And Revoking Of Registration: A Guide For Accountants & Tax Preparers

    EFILE is an electronic service that allows tax preparation service providers in Canada to file their clients' tax returns with the Canada Revenue Agency (CRA) directly from their tax preparation software.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    What To Do When CRA Refuses Taxpayer Relief – A Canadian Tax Lawyer's Case Commentary On Maverick V HMK, 2023 FC 1728

    Subsection 220(3.1) of the Income Tax Act provides the Canada Revenue Agency with broad discretion to grant taxpayer relief within the 10-year limitation period.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Economic Substance Doctrine [§7701(o)]: Critical Developments And Policy Implications To Prevent Abuse In U.S. Tax Law

    The Economic Substance Doctrine, codified under IRC §7701(o), is a critical anti-abuse rule in U.S. tax law. It ensures transactions have both a meaningful economic effect and a legitimate non-tax business purpose.
    United StatesTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    IRS Reporting Requirements For Foreign Exchange Bureaus: Your Complete BSA Compliance Guide For Currency Exchange Businesses

    Foreign exchange bureaus operating in the United States face rigorous IRS and FinCEN oversight due to their classification as Money Services Businesses (MSBs) under the Bank Secrecy Act (BSA).
    United StatesTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Latest Developments In U.S. Taxation Of Cryptocurrency: What American Crypto Traders, Crypto Investors Need To Know Now

    As crypto continues to evolve rapidly, so does the U.S. taxation of cryptocurrency, with the IRS and other federal agencies taking an increasingly active role in regulating and enforcing compliance with tax and all other applicable laws.
    United StatesTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Acquisition Of Real Estate: Taxation For Canadian Non-Resident Owners

    Purchasing Canadian real estate is often a popular and profitable type of investment for both Canadian and non-Canadian residents.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Upward Adjustments For Tax Notices Of Objection

    A tax Notice of Objection is a formal dispute filed with the Canada Revenue Agency wherein the taxpayer appeals tax amounts assessed against the taxpayer by the Canada Revenue Agency.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.

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