Canada’s anti-deferral regime and the FAPI rules: When offshore trust structures trigger more tax
A common misconception in offshore tax planning is that tax…
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Taxpayer sought judicial review of CRA’s decision to refuse changing his 2004 income tax return
In Rawlings v AGC, the taxpayer successfully won the right…
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CRA service levels 2026: Why the agency’s 70 per cent call-answering target is a problem for taxpayers
Moreover, a 70 per cent accessibility target effectively acknowledges that…
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Tax Court clarifies limits of director liability after corporate revival
The Tax Court of Canada has provided important guidance on…
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When taxpayer relief, CPP limitation periods, and procedural finality abandon fairness without a remedy
Tolley v The King is a reminder that developments after…
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When CRA employees misbehave and make mistakes against Canadian taxpayers
The Canada Revenue Agency distinguishes clearly between employee misconduct and…
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$3.2M tuna becomes a tax lesson: When are promotional ‘loss leaders’ tax deductible in Canada?
Canadian tax law permits aggressive marketing strategies, but it requires…
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Case Commentary: HMK v. Quebecor Inc – Federal Court Of Appeal rejects GAAR challenge to using strategy of business losses
The FCA decision reaffirmed that tax efficiency alone does not…
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How to deduct “loss leaders,” other outrageous promotional expenses on your Canadian business taxes
What Canadian tax rules apply to the deductibility of promotional…
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Missing a CRA notice is not an excuse: Tax Court reinforces strict deadlines to GST objections
The Tax Court of Canada’s decision in Ng v. The…
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