How to unwind ‘deemed disposition’ for returning Canadian tax residents – guidance from a Canadian tax lawyer

Deemed disposition and reacquisition rules When you move from Canada, you may be subject to…

Published: October 27, 2025

Last Updated: October 27, 2025

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GAAR and Corporate Restarts: Madison Pacific Properties Inc. v. Canada, 2025 FCA 20

Introduction – GAAR and the Use of Corporate Losses The general anti-avoidance rule (GAAR) in…

Published: October 27, 2025

Last Updated: October 27, 2025

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How Life Insurance is Taxed in Canada: What You Need to Know Before Making Withdrawals, Claiming Benefits

Death is an inevitable end that awaits every individual, and no one knows the time…

Published: October 24, 2025

Last Updated: October 24, 2025

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When Late Filing Penalties Apply under Subsection 162(7) plus Your Track Record of Respecting CRA Filing Deadlines – Laurie v. The King (2025 TCC 130)

Foreign Property Reporting and the CRA’s Approach to T1135 Penalties Subsection 162(7) of the Income…

Published: October 22, 2025

Last Updated: October 22, 2025

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Doing Cross-Border Transactions? You’ll Need Form T106 to Report Them to CRA – guidance from a Canadian tax lawyer

What is Form T106? Form T106 is an information return required by the Canada Revenue…

Published: October 21, 2025

Last Updated: October 21, 2025

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What are Foreign Spin-off Shares? How to Report Spin-off Shares Under Section 86.1 of Canada’s Income Tax Act

Foreign spin-offs When a Canadian resident shareholder of a foreign corporation (the original corporation) receives…

Published: October 14, 2025

Last Updated: October 10, 2025

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Methanex Case and International ‘Treaty Shopping’ in Search of Better Tax Breaks: Lessons for Canadian Corporations

Overview: Court Confirms Key Principles around Beneficial Ownership, Corporate Residence, and Validity of Tax-Efficient Structures…

Published: October 10, 2025

Last Updated: October 10, 2025

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CRA Voluntary Disclosure Program (VDP): A Canadian Tax Lawyer’s Guide to the New Rules Effective October 1, 2025

Voluntary Disclosure Tax Lawyers At Rotfleisch & Samulovitch P.C., our team of experienced Canadian tax…

Published: October 1, 2025

Last Updated: October 1, 2025

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Case Comment: How a Taxpayer’s Reliance on Frivolous Tax Appeals, Statute-Barred Tax Challenges in Court Backfired – Boucher v. Canada, 2004 FCA 46

Introduction The Federal Court of Appeal’s decision in Boucher v. Canada, 2004 FCA 46, is…

Published: September 29, 2025

Last Updated: September 23, 2025

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