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 Revenue Agency (CRA) has expansive…

Published: June 13, 2025

Last Updated: June 13, 2025

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Can CRA Require a Taxpayer to Prepare Net Worth Audit Schedules Under the New Section 231.1?

Changes to Section 231.1 Subsection 231.1(1) of the Income Tax Act (ITA) outlines the powers…

Published: June 13, 2025

Last Updated: June 13, 2025

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Canadian tax consequences of a foreign life insurance policy: CRA’s Form T1135 and reporting requirements – Canadian tax lawyer explains what you need to do

Who needs to file T1135? All Canadian resident taxpayers must file Form T1135 if, at…

Published: June 10, 2025

Last Updated: June 10, 2025

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How an Heir was Taxed 75% by the UK, Spain on his Inheritance (Just Crumbs Left) and How Tax Treaties Prevent Double Taxation

Recently, an X [formerly Twitter] user shared a post about his client, who was a…

Published: June 4, 2025

Last Updated: June 4, 2025

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Case Analysis: Why a Business Must Demonstrate Actual Business Activities Before Applying for Business Tax Deductions – Lienaux v. The King

Background On Charles Lienaux’s 2019 Business Expense Claims Charles Lienaux, a chartered professional accountant, claimed…

Published: May 22, 2025

Last Updated: May 22, 2025

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How are Group Benefit Plans Taxed for Employers? How are Group Benefits Taxed for Employees? What is Taxable? Non-Taxable?

Introduction: Taxation of Group Benefit Plans Benefits are non-monetary compensation that employers provide to employees.…

Published: May 16, 2025

Last Updated: May 16, 2025

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How the Mutual Agreement Procedure (MAP) Can Help Businesses and Individuals Resolve Cross-Border Tax Problems, plus tips from Canadian Tax Lawyer

Introduction: The Mutual Agreement Procedure (MAP) Is A Dispute Resolution Mechanism For Cross-Border Tax Issues…

Published: May 6, 2025

Last Updated: May 14, 2025

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Case Commentary: Court-Ordered Immediate Seizure (‘Jeopardy Order’) of Taxpayer Assets when Canada Revenue Agency Suspects Fraud, Tax Evasion – Canada (National Revenue) v. Ne’eman Foundation Canada, 2024 FC 1932

What is a Jeopardy Order? A jeopardy order is a court-issued order under section 225.2…

Published: May 5, 2025

Last Updated: May 5, 2025

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Chad v the King – Losses, expenses arising from transactions that are not ‘sufficiently commercial’ may be ineligible to reduce your income tax

INTRODUCTION: Businesses using artificial tax plans without considering business realities may face unintended consequences. The…

Published: April 28, 2025

Last Updated: April 28, 2025

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