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An Effective Tax Solution

Individuals, businesses of all sizes, organizations and even charities will face tax issues from time to time.

Tax Planning

Tax planning for business or for individuals and families is an ongoing process to reduce the overall taxes owing by the business.

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Tax Audits & Problems

A CRA audit is the start of the tax investigation and a Canadian taxpayer needs professional representation from the start.

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Voluntary Disclosure

The voluntary disclosure program allows you to avoid prosecution or penalties for unreported income or offshore assets

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Unpaid Tax Debt & CRA Garnishment

The CRA can send a garnishee notice to your employer or can even seize your bank accounts if you owe them taxes.

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FIGHT CRA

An Effective Tax Solution

CRA can and does lien salary and seize assets and bank accounts without a court order. CRA can and does show up at your home and place of business.

Our top canadian tax lawyers will protect your rights and will fight for you.

Unpaid Tax Debt & CRA Garnishment

Tax Court Appeals

What Our Clients Say

I’ve used Rotfleisch & Samulovitch for complex tax planning matters over the past few years. I’ve found them to be extremely knowledgeable, professional & effective, and would highly recommend them especially for entrepreneurs and their companies. R&S’ legal tax knowledge are a solid complement to the expertise of a quality accountant.

Mark Barnicutt

Toronto, Tel Aviv

If you have not filed your Canadian tax returns, or if you have filed them and CRA believes that you have not reported all of your income, they may issue a new worth assessment. They take two financial snapshots, one at the start of the audit period and one at the end. They add your reported income and expenditures to the opening financial position and subtract loans. If the amount is less than your closing net worth they will assess you for tax, penalties and interest on the difference. Net worth assessments require an understanding of the accounting behind the CRA calculations and the proper inclusions and exclusions from the opening and closing balances. Our firm has a track record of fighting these assessments.

If the amount is less than your closing net worth they will assess you for tax, penalties and interest on the difference. Net worth assessments require an understanding of the accounting behind the CRA calculations and the proper inclusions and exclusions from the opening and closing balances. Our firm has a track record of fighting these assessments.

If you have not filed your Canadian tax returns, or if you have filed them and CRA believes that you have not reported all of your income, they may issue a new worth assessment. They take two financial snapshots, one at the start of the audit period and one at the end. They add your reported income and expenditures to the opening financial position and subtract loans.

If the amount is less than your closing net worth they will assess you for tax, penalties and interest on the difference. Net worth assessments require an understanding of the accounting behind the CRA calculations and the proper inclusions and exclusions from the opening and closing balances. Our firm has a track record of fighting these assessments.

HOW TO

If you have not filed your Canadian tax returns, or if you have filed them and CRA believes that you have not reported all of your income, they may issue a new worth assessment. They take two financial snapshots, one at the start of the audit period and one at the end.

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Will the pandemic affect your taxes?

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Or Talk to a Toronto Tax Lawyer Now

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Frequently Asked Questions

Lawyers provide different expertise than accountants. If there are legal issues, such as an entitlement to a deduction or possible penalties or criminal charges, you need a lawyer to help you with your tax audit. You will also often need an accountant to work with your tax lawyer.You also need a tax lawyer to provide you with Solicitor client privilege to prevent CRA from seizing documents from you or from your Accountant.

You need a tax lawyer whenever the CRA is threatening you with penalties or tax prosecution. You should also be represented by a tax lawyer whenever there are legal tax issues in dispute, such as a limitation period or right to a deduction. If you want to reduce your taxes owing through tax planning you should also retain a tax lawyer. Finally, you need a tax lawyer to ensure solicitor client privilege to prevent the CRA from seizing documents from you or your accountant.

The 2020 tax filing deadline for individuals has been extended in Canada. It is now June 1st, 2020 instead of April 30th, 2020. For the self-employed it is June 15th, 2020. The CRA are also giving people slightly more time to pay their 2019 taxes. These deadline extensions were put in place because of the CoVid 19 crisis.

To appeal a Tax Court decision in Canada you have to file your appeal by sending a notice to the Tax Court of Canada office. This can be done in-person or via the mail, a fax or electronically. However, you do it, you need to ensure everything is filled out correctly and that you keep proof that you have filed it properly. It is easy to make a mistake, which is why many people hire a lawyer to do it.

How long a Notice of Objection that has been filed with the CRA takes to process varies considerably. It depends on the complexity of your case and the workload of the CRA. Low complexity cases can take around 57 days to resolve. But, more complex cases take about 500 days. This does not include the days the CRA is waiting for the taxpayer to provide additional information. A tax lawyer can liaise with your appeals officer to keep things moving.

It is still possible to set up a testamentary trust, in Canada. But, recent changes in the tax rules took away many of the benefits of doing so. However, an experienced tax lawyer will be able to explain whether you are one of the people who could still benefit from doing so. They can also assist you in setting up a testamentary trust. Or, if more appropriate, one of the 33 different types of living trusts that are available.

A testamentary trust allows you to control how your beneficiaries receive income or capital over time after your death. Also a single testament. The main benefit of a testamentary trust is that it allows you to control how your beneficiaries receive income or capital over time after your death. It is especially useful if you are leaving money to a minor or someone who is bad with money because you can stop them from spending it all at once. Also, a single testamentary trust can be taxed at lower rates. You need a legal professional to be able to set one up.y trust can be taxed at lower rates.

The main difference between living and testamentary trusts is that living trusts avoid the probate process. Assets in a living trust can be moved into the ownership of beneficiaries without court involvement. Both are good tools for controlling how assets are managed after death. But seek legal advice when deciding which to use. A testamentary trust is created in a will while a living trust, called inter vivos, is set up by a live person.

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Pro Tip

CRA Tax Audits

There are over 350,000 tax audit and review actions conducted by the Canada Revenue Agency on a yearly basis. Around 15,000 of these tax audits deal with “cash only” businesses (i.e. the underground economy). Additionally, an estimated 35,000 are tax shelter audits.

Get your CRA tax issue solved


Address: Rotfleisch & Samulovitch P.C.
2822 Danforth Avenue Toronto, Ontario M4C 1M1