Questions? Call 416-367-4222

The Supreme Court of Canada has confirmed that it has never held that the economic realities of a situation can be used to recharacterize a taxpayer’s bona fide relationships. It has held that, absent a specific provision of the Income Tax Act to the contrary or a finding that they are a sham, the taxpayer’s legal relationships must be respected in income tax cases.


"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."

Get your CRA tax issue solved

Address: Rotfleisch & Samulovitch P.C.
2822 Danforth Avenue Toronto, Ontario M4C 1M1

Taxpayer’s Legal Relationship For Tax
CRA Users Locked Out of their My Account: Canadian Tax Lawyer Guide
CRA Users Locked Out of their My Account: Canadian Tax Lawyer Guide
Seeking Punitive Damages from the CRA | Rotfleisch & Samulovitch PC
Tax Inquiry for Penalty has Charter Protection
Income Tax Collection Limitation Periods
Gordon v. Canada – Taxpayer Relief Canadian Tax Lawyer Case Comment
Man with glasses and pink dress shirt at desk with a laptop and income tax documentation on a clipboard
Canadian Taxpayer Rights: Toronto Income Tax Lawyer Analysis
Taxpayer Bill of Rights and Taxpayers’ Ombudsman
Non-Resident Withholding Tax – Interest Income – A Toronto Tax Lawyer Analysis