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  • Article

    Canada Revenue Agency Tightens Oversight On Cryptocurrency Transactions: What You Need To Know Now

    In recent years, the explosive growth of cryptocurrency has attracted the attention of investors, entrepreneurs—and now, tax authorities.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How The Canada Child Tax Benefit And The Child Disability Benefit Operate – A Canadian Tax Lawyer Explains

    The Canada Child Benefit (CCB), also referred to as the Canada Tax Benefit (CTB) or Canada Child Tax Benefit, is a tax-free payment made by the Canada Revenue Agency (CRA) every month to eligible families.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Guide For Canadian Property Owners Part II: Tax Liability When Selling Property

    2024 has been a difficult year for many property owners in Canada, in light of the high mortgage rates, increased capital gains tax, and the slow real estate market.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Primer On Tax Evasion And How To File Voluntary Disclosure Application – Guidance From A Canadian Tax Lawyer

    A Surrey, B.C. accountant has been sentenced to a two-year conditional sentence followed by two years of probation after pleading guilty to tax evasion, the Canada Revenue Agency (CRA) announced.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canadian Tax Treatment Of Stock Splits And Consolidations – A Canadian Tax Lawyer's Perspective

    A stock split is where a corporation exchanges one share of the corporation for multiple shares of the corporation.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Perspective On Income Tax Voluntary Disclosure Relief

    The Canada Revenue Agency's voluntary disclosure program allows taxpayers to come forward proactively to correct prior errors or omissions with their taxes.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    CRA Income Tax Penalties – Failure To File Tax Returns Electronically Penalties –Toronto Tax Lawyer Analysis

    The Canadian Income Tax Act requires certain corporations to file their annual income tax returns electronically.
    CanadaTax
    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.
  • Article

    Gordon Et Al v The Queen – Canadian Tax Lawyer's Analysis And Comments

    The plaintiffs, Allan Jay Gordon, James A. Deacur and Associates Ltd. [and James Allan Deacur sought damages from the government of Canada alleging that the Canada Revenue Agency conducted tortious act in its criminal investigation.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    What Is CRA's Regulation 105? An Overview On Withholding Tax On Payments To Non-Residents, Explained By Canadian Tax Lawyer

    When non-residents provide services in Canada, a lesser-known but critical piece of tax legislation comes into play: Regulation 105 of the Income Tax Regulations.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    When Full Business Income Tax, Other Than Capital Gains Tax, Is Payable If Business Activities Are Based On A "Secondary Intention" Tax Law Doctrine In An "Adventure In The Nature Of Trade" – Guidance From A Canadian Tax Lawyer

    The tax treatment of income in Canada depends on its classification, making it essential for taxpayers to understand the nature of the income they earn in order to file tax returns accurately and engage in effective tax planning.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    The Medical Expenses Tax Credit – Tax Planning For Optimizing Your Tax Claim – A Toronto Tax Lawyer Analysis – Part II

    In part I of this article about optimizing your medical tax credit claim through tax help from our expert Toronto tax lawyers, we discussed the requirements of the medical tax credit...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • 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

    Builders Of Real Property Are Liable For GST/HST Tax Payments

    Navigating the complexities of the Canadian tax system can be particularly challenging when dealing with real property transactions, especially in the realm of GST/HST obligations.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canada-US Tax Treaty – A Canadian Tax Lawyer Analysis

    Canada Revenue Agency levies income taxes on two bases. The first basis is on persons who have close ties to Canada – where such persons are residents of Canada.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Top 2016 Year End Income Tax Planning Tips By Canadian Tax Lawyer Part 2

    The charitable sector is key to the quality of life for many Canadians, and it relies on donations from ordinary Canadians in order to function. In this Part 2 of our year end tax planning article our expert Canadian tax lawyers discuss year end income tax planning for charitable donations
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    CRA Finally Unveils 100-Day Service Improvement Plan For 2025: How Canadian Taxpayers Should Benefit

    In 2025, Canadians faced prolonged delays with the CRA, including call answer rates below 40%in July 2025 and lengthy processing backlogs for T1 tax adjustments.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Voluntary Disclosure Applications: Canadian Tax Lawyer's Guide

    The Voluntary Disclosures Program, also known as tax amnesty, is a program offered by the Canada Revenue Agency that encourages a taxpayer to voluntarily come forward and disclose any inaccurate or unreported information concerning tax filings.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Guide On Net Worth Assessments – Halls V The Queen, 2022 TCC 14

    Net worth assessments may be undertaken by the tax auditor when the CRA considers a taxpayer's return to be inaccurate or when the taxpayer has not kept adequate records of the taxpayer's income for one or more years.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Perspective On Losses And Loss Determinations

    When a taxpayer receives an assessment or reassessment where the losses assessed differs from the taxpayer's filing position, the taxpayer can request a loss determination under subsection 152(1.1) of the Income Tax Act.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.

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