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Your search for ‘Rotfleisch & Samulovitch P.C.’ returned 1,530 results

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  • Article

    How To Claim Losses From Cryptocurrency Investment Schemes And Scams On Your Tax Returns – Guidance From A Canadian Tax Lawyer

    In October 2024, the US government revealed that the FBI created a cryptocurrency as part of an investigation into price manipulation in crypto markets.
    CanadaTechnology
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    What Landmark Israeli Transfer Pricing Case, Hexadite Ltd. v. Israel Tax Authority, Means For U.S. Multinationals

    The Israeli District Court decision in Hexadite Ltd. v. Israel Tax Authority provides important lessons on transfer pricing, valuation of intangibles, and post-acquisition business-model changes.
    United StatesTax
    Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
  • Article

    A Primer On Tax Rules For Syndicates: Courts Look Beyond Roles To Purpose, Profit

    In Canadian tax law, members of a syndicate are generally treated the same when it comes to the tax consequences of their collective activities. The Income Tax Act does not define or explain the treatment of syndicate members.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Treaties Impacting On Taxation: A Canadian Tax Lawyer's Perspective

    Taxation has become an increasingly global issue as people, money and property move freely across borders.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Taxation For eBay & Resellers: Canadian Tax Lawyer's Guide

    Resellers may take up reselling as a hobby, side business or even their main source of income.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    The Tax And Other Benefits & Challenges Of Practicing Law In Ontario As A Professional Corporation – Canadian Tax Lawyer Analysis

    Under the Law Society Act and the Business Corporations Act (Ontario), lawyers and licensed paralegals are permitted to practice law and provide legal services in Ontario through...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    401(k) Retirement Plans: Expert Strategies For U.S. Employees And Employers From A U.S. Tax Lawyer

    A 401(k) plan is the cornerstone of retirement savings for millions of Americans, offering tax-advantaged contributions, employer matching, and long-term investment growth, and is best used in conjunction with professional tax planning.
    United StatesTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canadian Snowbirds Should Know These US Tax Residence Rules – Tips from A Canadian Tax Lawyer

    If none of the factors are conclusive which is a very rare situation, you must ask the competent authority of each country to make a decision.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Learn Why The Tax Court Denied $118,000 In Employment Expense Deductions And The Record-keeping Lessons From Chennenkunnath v. The King

    A commission-based car salesman’s attempt to deduct over $118,000 in employment expenses across two tax years was blocked in Chennenkunnath v. The King, 2026 TCC 112.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Refunds: Corporate Tax Credits From Closed Tax Years - Re-Appropriation Of Amounts – A Canadian Tax Lawyer Analysis

    When a taxpayer files a tax return within 3 years of the end of the taxation year, the Canada Revenue Agency ("CRA") is obligated to refund to the taxpayer any overpayments of tax.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    2018 Federal Budget – Passive Income In Private Corporations – A Toronto Tax Lawyer Analysis

    Though both may end up paying a similar tax rate on the income generated by their investments, the CCPC would be earning more income due to its higher starting capital.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    TFSA Non-Residence Contribution Tax Cancellation – A Toronto Tax Lawyer Analysis

    For Canadians who are planning their retirement by investing their savings, the Tax-Free Savings Account (TFSA) has become an important supplement to the Registered Retirement Savings Plan (RRSP)
    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

    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

    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

    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

    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

    Back-To-Back (B2B) Loans – Withholding Tax Rates On Interest, Rents, And Royalties

    For individuals or corporations that are not tax residents in Canada, certain payments that they receive from Canadian sources are subject to withholding taxes.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Director's And Officer's Tax Liability When Serving On Boards—and Resigning To Prevent Corporate Tax Liability

    A director of a corporation may be held personally liable when the corporation fails to deduct, withhold, remit, or pay certain taxes.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Showing 661–680 of 1530 results

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