Doing Cross-Border Transactions? You’ll Need Form T106 to Report Them to CRA – guidance from a Canadian tax lawyer

What is Form T106? Form T106 is an information return required by the Canada Revenue…

Published: October 21, 2025

Last Updated: October 21, 2025

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What are Foreign Spin-off Shares? How to Report Spin-off Shares Under Section 86.1 of Canada’s Income Tax Act

Foreign spin-offs When a Canadian resident shareholder of a foreign corporation (the original corporation) receives…

Published: October 14, 2025

Last Updated: October 10, 2025

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Methanex Case and International ‘Treaty Shopping’ in Search of Better Tax Breaks: Lessons for Canadian Corporations

Overview: Court Confirms Key Principles around Beneficial Ownership, Corporate Residence, and Validity of Tax-Efficient Structures…

Published: October 10, 2025

Last Updated: December 9, 2025

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CRA Voluntary Disclosure Program (VDP): A Canadian Tax Lawyer’s Guide to the New Rules Effective October 1, 2025

Voluntary Disclosure Tax Lawyers At Rotfleisch & Samulovitch P.C., our team of experienced Canadian tax…

Published: October 1, 2025

Last Updated: October 1, 2025

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Case Comment: How a Taxpayer’s Reliance on Frivolous Tax Appeals, Statute-Barred Tax Challenges in Court Backfired – Boucher v. Canada, 2004 FCA 46

Introduction The Federal Court of Appeal’s decision in Boucher v. Canada, 2004 FCA 46, is…

Published: September 29, 2025

Last Updated: September 23, 2025

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Canada’s 2025 Draft Tax Legislation Overview

Introduction: Overview of Canada’s 2025 Draft Tax Legislation On August 15, 2025, the Department of…

Published: September 26, 2025

Last Updated: September 23, 2025

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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 digital tools and artificial intelligence…

Published: September 25, 2025

Last Updated: September 23, 2025

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The 7 Steps of Estate Administration in Canada – Guidance from a Canadian tax lawyer

When an individual passes away, the property and assets s/he leaves behind are collectively referred…

Published: September 24, 2025

Last Updated: September 23, 2025

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Agreements Must be in Writing: Hutchings v. The King (2025 TCC 108), a Case of COVID-19 Rent Subsidies

Canada Emergency Rent Subsidy Lessons: Verbal Agreements Left Businesses Without Relief The COVID-19 pandemic forced…

Published: September 23, 2025

Last Updated: September 23, 2025

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