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Published: November 8, 2023

David Rotfleisch is a certified tax law specialist and founder at Rotfleisch & Samulovitch in Toronto.


“If you are the CRA, and you’re auditing a taxpayer, to some extent, you’re a blind man exploring an elephant,” says Rotfleisch. “They can assume facts. The reason being that they don’t know the facts. We are in possession of all of the facts because they’re coming in and auditing us and investigating us. They don’t entirely know what happened, so they are allowed to make assumptions in their pleadings.”


"This article provides information of a general nature only. It is only current at the posting date. It is not updated and it may no longer be current. It does not provide legal advice nor can it or should it be relied upon. All tax situations are specific to their facts and will differ from the situations in the articles. If you have specific legal questions you should consult a lawyer."

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