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Rotfleisch & Samulovitch P.C. has helped 1,000s of clients fight the CRA, solved their tax problems and implemented effective tax planning solutions to reduce their tax burden. By staying focused and specialized, the Canadian tax lawyers at are able to respond quickly and effectively to our clients’ income tax issues and concerns as they arise. Whether it’s dealing with a CRA tax auditor or unreported offshore income, there’s just one answer to a tax problem – an effective and custom tax solution that’s just right for you. Contact us to see what we can do for you today!

Description: HST case. Client corporation had paid suppliers but invoices issued to related corporation.

Outcome: Settlement during the discoveries process to allow all input tax credits claimed.

Description: Canada Revenue Agency refused to assess a taxation year of client for more than 4 years pending the outcome of audit of business activities, leading to denial of carrryforwards/carrybacks and robbing him on right to exercise his appeal rights to the Tax Court of Canada.

Outcome: Settlement achieved prior to discoveries and CRA assessed the year as demanded in the judicial review application.

Description: Client assessed for allegedly unpaid Tobacco Tax on cigarettes at her convenience store.

Outcome: Settlement prior to hearing vacating the entire amount assessed and repayment of assessed amount with interest

Description: CRA denied the Corporation's small business deduction. CRA alleged that the Corporation was a "specified investment business,"

Outcome: Settled prior to hearing: small business deduction allowed in full. Saved the client over $45,000 in corporate income tax

Description: Client had significant cash deposits in his bank account which CRA claimed to be unreported income and assessed additional tax owing and gross negligence penalties.

Outcome: Gross negligence penalties waived

Description: Client had purchased and lived in a property for approximately a year after having gone through a divorce before selling the property and moving elsewhere. The CRA denied the client’s PRE claim on the sale of the property

Outcome: Settlement prior to Court, principal residence exemption allowed and all penalties waived

Description: The sole issue is whether a business investment loss was properly claimable in the year by the Appellants in respect of amounts owed to them by Fran Restaurants Limited.

Outcome: Appeal from assessment made under the ITA for the 1997 taxation year is allowed with costs and the assessment is referred back to the Minister for reconsideration and reassessment. Assessment in respect of each Appellant is referred back to Minister on the basis that the full amount of their respective advances as agreed to were business investment losses in 1997.

Description: Issue in this appeal by Appellant is whether or not she was dealing at arm's length with 470555 Ontario Limited for purposes of ss. 160(1) of the ITA when you Corporation paid her a dividend in 1996 at the time the corporation was liable to pay tax. The Appellant is of the view that she did deal at arm's length when the dividend was declared on January 16, 1996 and paid on January 17, 1996 notwithstanding that she was a shareholder and director at the time.

Outcome: The appeal from the assessment made under ss.160(1) the ITA dated January 30, 1998 and numbered 00067 is allowed, with costs, and the assessment is vacated.

Description: Respondent (Crown) seeks an order striking this application essentially on the basis that as the matters in dispute deal with “assessments” those are matters that are within the sole jurisdiction of the Tax Court. Thus, there is no jurisdiction for this application to be heard in this Court and must be struck.

Outcome: The motion was dismissed without cost. The Respondent was granted an extension of time of 30 days within which to file its responding affidavit and documentary exhibits.

Description: The Applicant (taxpayer) seeks judicial review, pursuant to s. 18.1 of the Federal Courts Act, of the decision by the CRA (Respondent) made on April 11, 2007, which determined that the Applicant did not qualify for interest and penalty relief under the voluntary disclosure program (VDP) administered by the CRA under ss. 220(3.1) of the ITA.

Outcome: Decision made by the CRA was considered unreasonable and set aside. Costs are to the Applicant.

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