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Your search for ‘Rotfleisch & Samulovitch P.C.’ returned 1,532 results

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  • Article

    U.S. Life Insurance Withdrawals: Tax Implications And Strategies

    Permanent life insurance policies—such as whole life, universal life, and variable life—are valuable financial tools that provide both protection and cash value accumulation.
    United StatesTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Using COVID-19 Benefits Fraudulently Will Get You Charged With Tax Evasion By The CRA

    Leslie Sand of Brooks, Alberta, has been sentenced to 3.5 years in jail and fined nearly $800,000 for defrauding the Canada Revenue Agency (CRA) through fake COVID-19 subsidy claims and tax evasion.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
Article

How To Best Leverage Small Business Investment Corporations: Section 150.1(2.1) Of The Income Tax Act

Section 150.1(2.1) of the Income Tax Act (the "Tax Act") mandates prescribed corporations file electronic tax returns. A "prescribed corporation" is defined under s.205.1(2) of the Income Tax Regulations (the "Regulations").
CanadaTax
Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
  • Article

    Consequences Of Failure To File Valid Business Limit Allocation Agreement With CRA And Missing Out On The Small Business Deduction

    A Canadian-controlled private corporation (CCPC) is defined in subsection 125(7) of the Income Tax Act as a private corporation resident in Canada, not controlled directly or indirectly by a non-resident, a public corporation, or a combination of the two.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Charging GST/HST On Digital Marketing Income In Canada: AdSense, NFTs, And Zero-Rating Risks

    Canadian taxpayers, including content creators, influencers, and digital entrepreneurs, who earn income from digital marketing activities—including online advertising through platforms such as Google AdSense, promotional services linked to NFT projects, and sponsorship arrangements with offshore entities—often assume that this income is not subject to GST/HST or is automatically zero-rated because it involves non-Canadian counterparties.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Federal Court Upholds The Canada Revenue Agency's Audit Powers In The Face Of Charter Challenge: Campbell v Attorney General Of Canada, 2018 FC 683

    Campbell v Attorney General of Canada (2018 FC 683) provides yet another example of the futility in resisting a Canada Revenue Agency tax audit.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    What's The Limitation On Losses Of Shares Held As Capital Property For Individuals And Corporations? Canadian Tax Lawyer Explains

    Subsection 112(3) of the Income Tax Act is a stop-loss rule that limits losses from the disposition of shares held as capital property.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Comparing The U.S. Voluntary Disclosure Program To Israel's New Tax Disclosure Plan

    Tax authorities worldwide continue to refine their voluntary disclosure programs to encourage taxpayers with unreported income to come forward. Israel recently launched a new disclosure plan focusing on cryptocurrency and high-value assets.
    United StatesTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Compensation For Business Owners: How Benefits Are Taxed For Shareholders And Shareholder-Employees

    It is not uncommon within incorporated family businesses or other closely-held private corporations for the shareholders of that business to also act as the employees of the corporation's business.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Court Need Not Recognize A Foreign Court's Rectification Order For It To Bind The Canada Revenue Agency: Canadian Forest Navigation Co. Ltd. v Canada, 2017 FCA 39

    Rectification boasts one important difference from a mere amendment. Unlike a document amended by the parties themselves, a rectified document can undo a tax consequence resulting from its pre-rectified form.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Canadian Tax Lawyer's Guide On 'Part XIII' Withholding Tax On Non-Residents Who Receive Property Income From Canadian Residents: A Case Study Of 3792391 Canada Inc. v The King

    The Tax Court of Canada in 3792391 Canada Inc. v The King, 2023 TCC 37, found the tenant to be liable for a failure to withhold and remit tax on rental payments made to the tenant's non-resident landlord.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Guide To Canadian Corporate Dividend Tax Strategy

    For Canadian small business owners, determining the most tax-efficient method to draw income from a corporation is a key strategic challenge.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Case Commentary: GST/HST Not Owing On Renovation Because Definition Of "Substantial Renovations" Of Property Not Met – 2437299 Ontario Inc. vs. The King

    If a building meets the definition of being substantially renovated under subsection 123(1) of the Excise Tax Act, and is part of a residential complex, then it may be treated as a new house for GST/HST purposes.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Case Commentary: Schwarz v. HMK – You Must Appeal Within The Deadline For Tax Reassessments; The Tax Court Cannot Forgive Tax Debt

    In June 2025, the Tax Court of Canada (TCC) handed down the decision in Schwarz v. HMK, 2025 TCC 86, dismissing the taxpayer's request for an extension of time to file an appeal in respect of his 2008 to 2014 taxation years.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Case Commentary: Watts v The King, 2024 TCC 100 – Enhanced Costs Of Litigation

    In August 2024, the Tax Court of Canada delivered its judgment in Watts v The King, 2024 TCC 100, awarding the Crown (CRA) costs beyond the standard tariff amounts, commonly referred to as "enhanced costs," in a lump sum of $30,000.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Changes To Canada's Alternative Minimum Tax (AMT) Target High Income Earners

    Recent changes to the Alternative Minimum Tax (AMT) in Canada could have significant implications in various tax planning areas. Understanding how these changes affect your tax situation is crucial for minimizing your tax liability.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    CRA Tax Audit Of Loss Carryovers Exceeding $200,000

    In R v Posteraro and Dyck, 2014 BCPC 31, a voir dire about the admissibility of evidence in criminal proceedings for tax evasion, the CRA revealed that it had an internal policy to audit any loss carryover claim exceeding $200,000.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Cross-Border Tax Lawyer On Trump's 'One Big Beautiful Bill' (OBBB): Key Impacts For Canadians

    The United States' One Big Beautiful Bill (OBBB), signed into law in 2025, represents a sweeping tax overhaul for individuals and corporations.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How To Navigate Tax Incentives For First-Time Home Buyers: Tax Tips From A Canadian Tax Lawyer

    Entering the housing market is not easy these days and this is true in many communities across Canada. Prices are high, competition is stiff and market conditions seem to shift quickly.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Ontario Non-Resident Speculation Tax—A Canadian Tax Lawyer Analysis

    A taxpayer is subject to many types of taxes and the rules for each type of tax are laid out in a piece of legislation.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Showing 761–780 of 1532 results

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