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Category: CRA Tax Audit

  • CRA Tax Audit
  • Tax Appeals and Litigation

How a CRA Tax Audit that uses Bank Deposit Analysis Affects Tax Reassessments in Canadian Tax Litigation: Comparing Premier Fasteners Inc. v The King and Hickman Motors Ltd. v Canada

The Tax Court of Canada decision in Premier Fasteners Inc.…
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  • CRA Tax Audit

CRA’s Tax Audit Powers Are Expanding: What Canadian Businesses Need to Know in 2026

Overview of Enhanced CRA Tax Audit Mechanisms for Tax Compliance…
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  • CRA Tax Audit

What Businesses Need to Know about Expanding Minister of National Revenue Powers during Reassessments Under Income Tax Act, Subsection 152(9) – Perspective from Canadian Tax Lawyer

Expert Canadian Tax Lawyer Insights into Tax Court of Canada…
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  • CRA Tax Audit

CRA’s Increasing Use of Digital Tools and AI Analytics to Enforce Penalties: What Canadian Taxpayers Need to Know Now

Overview The Canada Revenue Agency (CRA) is increasingly adopting advanced…
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  • CRA Tax Audit

Landmark Canadian Tax Law Decision that Limits CRA’s Authority Under Section 231.2 of Income Tax Act: Canada (National Revenue) v Shopify Inc., 2025 FC 968

Introduction: Section 231.2 of the Income Tax Act The Canada…
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  • CRA Tax Audit

Do I Have to Submit to an Oral Interview During a Tax Audit? Canadian Tax Lawyer Explains CRA’s Policy

Introduction: CRA’s Power to Compel Oral Interviews Starting from December…
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  • CRA Tax Audit
  • Tax Penalties

Choptiany et. al. v The King, 2022 TCC 112: The Tax Court of Canada Issues Scathing Rebuke of CRA’s “Outrageously Misleading and Inappropriate” Litigation Tactics in Tax Dispute Involving Gross-Negligence Penalties

Introduction: The Canada Revenue Agency’s Overzealous Use of Gross-Negligence Penalties Gross-negligence…
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  • bitcoin and cryptocurrency
  • CRA Tax Audit
  • voluntary Disclosure

Canadian Tax Implications of The Ethereum Merge: A Guide from a Canadian Tax Attorney

The Long-Awaited “Ethereum Merge” a Success - An Introduction The…
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  • CRA Tax Audit

Tax Lawyer Analysis: CRA’s Broad Powers to Compel Third Party Information under Section 231.2 is Not Without Limits

Section 231.2: CRA’s Broad Powers to Compel Information from Third…
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  • CRA Tax Audit
  • Taxation of Ebay & Other Shared Economy Income
  • voluntary Disclosure

OnlyFans Taxes in Canada & Other Social Media Revenue: Guidance from a Canadian Tax Lawyer

Introduction – What is OnlyFans? In 2016, British entrepreneur Timothy…
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