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

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  • Article

    A Canadian Tax Lawyer's Perspective On Dale Et Al. v The Queen -Timing On Issue Of Shares In Section 85 Rollover

    Bernard and Peter Dale jointly owned a building. The Taxpayers also owned 23 of the 26 shares of Dale Corporation, a corporation incorporated under the laws of Prince Edward Island, with the remaining shares being owned by ...
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Qualifying For Small Business Deduction: Canadian Tax Lawyer's Guide

    Since 1949 the federal government has afforded small businesses a reduction in income tax otherwise payable.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
Article

Tenants Beware: Not Remitting Withholding Tax On Rental Payments To Non-Resident Landlords Can Cost You Thousands: 3792391 Canada Inc. V. The King

When non-residents receive income from Canadian sources, such as dividends, interest, royalties, or rental income, the Canadian government imposes a withholding tax on this income.
CanadaTax
Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
  • Article

    The Ontario Ministry Of Finance's Voluntary Disclosures Program – A Canadian Tax Lawyer's Summary

    Under the Canadian tax law system, Canadian taxpayers are subject to income taxation at both the Federal and Provincial levels of government.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Where Are The Best Tax Residence Locations For A Crypto Investor?

    As of late 2024, the state of cryptocurrency is dynamic and evolving, influenced by a combination of regulatory developments, technological innovations, and market trends.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canadian Tax Lawyer Analyzes Voluntary Disclosure Programs Around The World – Part I: OECD Report On Voluntary Disclosure Program

    This is Part I of the series, which focuses the conceptual aspect of the tax voluntary disclosure programs around the world and discusses how tax voluntary disclosure programs have affected taxpayers and the governments.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A Taxpayer Need Not Answer Questions During A CRA Tax Audit: Minister Of National Revenue v Cameco Corporation, 2019 FCA 67

    MNR v Cameco Corporation (2019 FCA 67) shows that the Canada Revenue Agency's tax-audit powers—while broad—come with limits.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Accepting Money From A Spouse With Tax Problems Can Give You A Bigger Problem With CRA: Panneton v. The King (2024 TCC 24)

    The decision in Panneton v. The King is an important reminder of how strictly Canadian courts apply section 160 of the Income Tax Act.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Adjusted Cost Basis Traps In Corporate Life Insurance Planning: How To Avoid Nasty Capital Dividend Account Surprises

    In Canadian corporate tax planning, few concepts create as much confusion—or as much unexpected tax exposure—as the adjusted cost basis of a corporate-owned life insurance policy.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Be Very Afraid: The Canada Revenue Agency (CRA) Has Impressive Powers To Enforce Collection, Plus Penalties And Interest For Non-Compliance

    The Canada Revenue Agency (CRA) possesses a wide range of administrative and enforcement powers in carrying out its mandate as the nation's tax authority.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canadian Tax Lawyer Explains CRA's Policy Positions For Canada's New Property Flipping Rules

    In January 2024, the Canada Revenue Agency's Income Tax Rulings Directorate published its first two technical interpretations on the newly minted "house flipping" rules under section 12 of the Canadian Income Tax Act.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Case Commentary: Persaud v The King – When Can You Claim Tax Deductions (Including Medical Bills) For Dependants? Tax Residence In Canada Is Key

    Several provisions of Canada's Income Tax Act (the "Tax Act") allow individuals to claim medical expenses as a deduction. This includes subsection 118.2 of the Tax Act, which allows a taxpayer to claim medical expenses for a dependant.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Do Transfers To Agents Invoke Vicarious Tax Liability Under Section 160? A Canadian Tax Lawyer's Analysis

    Section 160 of the Income Tax Act is a tax collection tool. It thwarts a taxpayer's attempts at moving money beyond the tax collector's reach by placing it in presumably friendly hands.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Exemptions And Rebates (Section 20) Of The Non-Resident Speculation Tax (NRST) For Foreign Real Estate Investors – Guidance From A Canadian Tax Lawyer

    The Non-Resident Speculation Tax (NRST) was introduced to address concerns about non-resident investors purchasing Ontario homes primarily for speculative purposes.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    How To Reduce Double Taxation On An Estate Through The Loss Carryback Strategy: Intelligence From A Canadian Tax Lawyer

    When a loved one dies, taxes can impose a substantial and often unexpected burden on their estate.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Milne v The King, 2026 TCC 78 –When A Home-Based Business Is Not A “Qualifying Property” Under The Canada Emergency Rent Subsidy (CERS) Program

    Milne v The King is a 2026 decision from the Tax Court of Canada regarding taxpayer eligibility for the Canada Emergency Rent Subsidy (“CERS”) program in which the taxpayer operated a business out of a dedicated portion of his home.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Principal Residence Exemption From Taxation Of Cottages

    With Canadians limited from foreign vacations and many Canadians working remotely over the past year due to the COVID-19 pandemic, there has been a boom in purchasing cottages and other recreational properties.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Proposed Changes To The Voluntary Disclosures Program (VDP) – Conditions Of A Valid Disclosure – A Canadian Tax Lawyer Analysis

    On Friday June 9 CRA released proposed changes to the Voluntary Disclosures Program (VDP or Canadian Tax Amnesty).
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    The Specialized Tax Attribution Rules: Indirect Payments, Tax On Split Income, Corporate Attribution, And Revocable Trusts—A Canadian Tax Lawyer's Guide

    This article describes more specialized tax-attribution rules in the Canadian tax system—specifically, those applying to diverted payments, income-splitting with minors, holding corporations, and revocable trusts.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    U.S. Profits Interests: What Are They & How Are They Taxed In Canada?—A Canadian Tax Lawyer's Analysis

    For U.S. federal income-tax purposes, one may hold one of two sorts of interests in a partnership—or any entity that the U.S. taxes as a partnership, such as a limited liability company: a capital interest or a profits interest.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Showing 801–820 of 1532 results

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