Preston Family Trust II v The Queen: Guidance from a Canadian Tax Lawyer Regarding Assumptions of Facts in Replies to a Notice of Appeal

Taxpayers filed motions to strike out CRA’s assumptions in its replies to the notices of…

Published: November 8, 2022

Last Updated: November 8, 2022

Read More

Eight Estate Freeze Pitfalls & Tax Tips To Avoid Them – A Canadian Tax Lawyer’s Analysis

Here's the scenario: When a taxpayer dies, subsection 70(5) of Canada's Income Tax Act deems…

Published: November 7, 2022

Last Updated: November 7, 2022

Read More

New Housing Rebate: Guidance from a Canadian Tax Lawyer on the Issue of Primary Place of Residence

What is the new housing rebate? The new housing rebate is available to individuals who…

Published: October 26, 2022

Last Updated: October 31, 2022

Read More

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 penalties serve to reprimand taxpayers…

Published: October 21, 2022

Last Updated: November 7, 2022

Read More

6075420 Canada Inc. v M.N.R.: A Canadian Tax Lawyer’s Guidance on Reassessment Limitation Periods

Introduction – Exploring the Normal Reassessment Period and “Statute-Barred” Tax Years for a Canadian Taxpayer…

Published: October 18, 2022

Last Updated: October 18, 2022

Read More

Oddi v CRA: Guidance from a Canadian Tax Lawyer Regarding CRA’s Collection Misconduct

Taxpayer sought damages against the CRA for sale of property In Oddi v CRA, Mr.…

Published: October 11, 2022

Last Updated: October 28, 2022

Read More

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

The Long-Awaited “Ethereum Merge” a Success - An Introduction The Ethereum blockchain was successfully upgraded…

Published: October 4, 2022

Last Updated: October 4, 2022

Read More

How To Interpret a Tax Treaty – Guidance from a Canadian Tax Lawyer

What is a tax treaty A tax treaty is a bilateral agreement made by two…

Published: September 20, 2022

Last Updated: September 20, 2022

Read More

Can You Claim Business Expenses Without Supporting Documents: Guidance From a Canadian Tax Lawyer

A business owner is generally required to keep books and records for minimum of six…

Published: September 12, 2022

Last Updated: October 28, 2022

Read More