Articles
Israel’s Anticipated, Pilot Voluntary Disclosures Program Gets A Rocky Start — And Lessons From Canada’s Voluntary Disclosure Program (VDP)
In August 2024, the Israeli Tax Authority announced that its pilot voluntary disclosures program had…
When can the federal court quash abusive CRA decisions to assess taxes?
This article discusses 2024 case law in relation to the Federal Court's jurisdiction to quash…
Opinion: The taxman is coming for our homes
Governments don't tax capital gains on people’s homes, but they tax almost everything else about…
Employees Beware: Upcoming legislation affecting capital gains will impact employee stock options
David J Rotfleisch explains how Department of Finance changes to legislation, which are expected to…
Taxpayers Beware: CRA’s new tools for catching tax evasion, avoiding tax debt
As David J Rotfleisch explains, the most recent federal budget included plans to hold tax…
Why the John Tavares tax case means so much to pro athletes in Canada and the U.S.
“Tavares’s appeal represents a high-profile opportunity for the CRA to test the limits to structuring…
Guide to Canadian tax rules on benefits arising from use of corporate assets (e.g., money, trips, boats, cars, space trips, etc.)
What happens when business owners dip into their corporation's pockets to pay for personal expenses?…
What is the standard of review for discretionary decisions of the CRA appealed to the federal courts?
Canadian accountant and tax litigation lawyer David J Rotfleisch takes a deep dive into the…
Case Commentary: Persaud v The King – When can you claim tax deductions (including medical bills) for dependants?
Tax residence is key, says Canadian tax accountant and lawyer David J Rotfleisch, to claiming…
Canadian crypto tax cheats beware: the CRA is on the hunt
According to a report from the National Post, the Canada Revenue Agency is currently looking to collect…
CRA Collects $54 Million in Undeclared Crypto Transactions
The Canadian Revenue Agency (CRA) has tightened its inspection against tax evasion through cryptocurrencies. CRA…
Canada Revenue Agency Targets $39.5 Million From Crypto Tax Evaders
Amid these efforts, veteran tax lawyer David Rotfleisch criticizes the CRA’s current measures as merely…
Drop in the bucket’: CRA targets millions in unpaid crypto taxes, investigating hundreds of traders
A veteran tax lawyer and cryptocurrency specialist David Rotfleisch says the agency needs to do…
Tax Court Of Canada rejects CRA’s attempt to apply gross-negligence penalties in statute-barred years
Still, the CRA bears the burden of proving that the taxpayer committed fraud or made…
Feds to propose funding for CRA real estate audits in 2024 budget
Ottawa said it is targeting tax fraud in the housing sector. David Rotfleisch, tax lawyer…
CRA’s focus on real-estate audits paying off
David Rotfleisch, tax lawyer with Rotfleisch & Samulovitch Professional Corp. in Toronto, also acts for…
More than $55M has been lost to investment scams in Toronto over the last 9 months. Is ‘pig butchering’ making it worse?
David Rotfleisch, a tax lawyer in Toronto, said he’s met with more than a dozen prospective…
More than $55M has been lost to investment scams in Toronto over the last 9 months. Is ‘pig butchering’ making it worse?
This latest iteration of scam has proven a problem in Toronto and across the globe.…
Canadian Short-Term Rental Owners Face Hefty Tax When Converting to Lengthier Leases
One Canadian tax expert acknowledges the tax could discourage the return of long-term rentals from…
Canadian Toy Couch Maker Faces Hefty Tariffs After Onshoring Production
Business lawyer David Rotfleisch emphasizes the complexity of tariff classifications, noting that such wrong assessments…
Don’t miss out on these more obscure tax deductions
Northern residents’ deductions: “The cost of living in the North is high,” says David Rotfleisch, a…
This business owner brought most of her manufacturing home from China — and feels punished for it
It's not unusual for businesses to be caught in the complicated web of tariffs, according…
How international athletes are taxed in Canada: Toronto Maple Leafs’ captain John Tavares embroiled in tax litigation with CRA
But Tavares' headline-breaking appeal to the Tax Court of Canada in January 2024 piqued not only the…
‘I’m struggling’: Repayments of COVID-19 benefits leaving some Torontonians with little to spare
Toronto tax lawyer David Rotfleisch said he’s seeing, on average, about two to three people…
What to do when the CRA refuses taxpayer relief
Tax accountant and lawyer David J Rotfleisch explains how a corporate director won relief from…
How to handle cryptocurrency on tax returns
“[Cryptocurrency] is very much an evolving technology — evolving almost on a daily basis —…
How CRA taxes crowdfunding in Canada
Canadian tax lawyer David Rotfleisch explains CRA’s tax policy on 4 crowdfunding models: 1) remuneration-based…
Director held personally liable for unremitted and uncollected GST/HST — due diligence defence judged insufficient
Case commentary from Canadian tax accountant and lawyer David J Rotfleisch on the Tax Court…
Case Commentary: CRA violates procedural fairness for CERB/CRB claims
Canadian tax lawyer and accountant David J Rotfleisch examines the Federal Court decision in Cameron…
Ontario corporation disputes handling of Voluntary Disclosures Program
Our office was approached to represent an Ontario corporation after its request for penalty and…
Made a mistake on your tax return? Here’s how to change your Canadian tax return through the tax objections process
Canadian tax lawyer and accountant David J Rotfleisch explains the legal history behind the tax…
Made A Mistake On Your Tax Return? Here’s How To Change Your Canadian Tax Return Through The Tax Objections Process
Canadian courts have long recognized a taxpayer's right to object to a tax assessment reflecting…
When is it worth challenging the CRA’s defective Tax Court pleadings?
Tax accountant and lawyer David J Rotfleisch reconciles the Federal Court Of Appeal's decisions in…
A Canadian tax lawyer explains why the ATIP process is critical to preparing for tax disputes with CRA
An Access to Information or Personal Information (ATIP) request can be a double-edged sword despite…
Tax complexities in dealing with the death of a spouse: ODSP and child benefits
Canadian tax lawyer and accountant David J Rotfleisch looks at the concept of ghost income…
Canada Revenue Agency claws back $458 million in CEWs wage subsidies from COVID-19 pandemic following audits
The Canada Revenue Agency has revealed that $458 million in funds distributed to employers through…
Canada: Canada Revenue Agency Claws Back $458 Million In CEWs Wage Subsidies From COVID-19 Pandemic Following Audits
The Canada Revenue Agency (CRA) has revealed that $458 million in funds distributed to employers…
Taxpayers must articulate reasons for not responding to questions in motions in Tax Court
Richard Quigley v The King outlines the appropriate questions and responses during the discovery stage, explains…
Federal tax rules punishing farmers with other jobs, judge says
A federal judge lamented having to deny hundreds of thousands of dollars in tax deductions…
Tax obligations for foreign home buyers In Canada: Bakhtiari v British Columbia
Can a refugee avoid paying the foreign buyer’s tax on human rights grounds under the…
CRA’s 10% interest rate on overdue tax raises risks
Proposed legislation extends reassessment period.. The Canada Revenue Agency (CRA) is charging higher interest rates…
Clarification needed on CRA’s power to assume facts and law in tax litigation, says lawyer
David Rotfleisch is a certified tax law specialist and founder at Rotfleisch & Samulovitch in…
Canadian taxpayers, beware: The CRA gets away with defective pleadings during tax litigation
Yet in practice, the CRA's pleadings often mistakenly identify legal conclusions and statements of mixed…
Multimillionaire calls CRA negligent, wants $4.8M tax bill thrown out
The CRA does indeed have to send a notice of assessment or reassessment — within required…
Are hybrid sales of private businesses still a viable tax planning tool for business owners?
David J Rotfleisch explores whether the Foix decision by the FCA radically undermines the tax…
Canadian Tax Lawyer David Rotfleisch on How to Obtain (Exceptionally Rare and Discretionary) Tax Remission Order for Your Tax Debt, Tax Penalties, and Tax Interest
The Canadian Income Tax Act includes provisions that are meticulously drafted and precisely structured to…
Canadian taxpayer involved in a bad will investment scheme granted additional relief on accrued interest
Relief requests beyond the statute of limitation may still be available, depending on the circumstances, explains tax…
David Rotfleisch on Tax Obligations in Canada for Unreported Income from NFTs: Analyzing the Holy Rock NFT Creators’ Prosecution in Israel
In March 2023, the Israeli Tax Authority made an announcement regarding the apprehension of two…
SR&ED Tax Credits upheld by Tax Court Of Canada in Canafric Inc. v. The King
Developing new recipes qualifies for Scientific Research and Experimental Development credits, explains David J Rotfleisch,…
This Activity Could Put You Offside of TFSA Rules
While there is no definitive criteria or threshold to establish what investment activities constitute ‘regular…
Audio
Why have you put off filing your taxes?
CBC radio host Amanda Pfeffer asks tax lawyer and chartered accountant David Rotfleisch to analyze…
“Fight Back with Libby Znaimer,” Zoomer Radio
David Rotfleisch and Toronto Councillor Stephen Holyday discuss interest and penalties on late payments to the…
Canadian Tax Lawyer Calls on the Government to Extend the Tax Deadline on Zoomer Radio
Canadian tax lawyer David Rotfleisch was recently featured on Zoomer radio, along with other tax…
What does carbon pricing mean for you?
Prime Minister Trudeau announced on Tuesday the Liberals' federal carbon tax and rebate plan to…
Is the CRA treating you fairly?
The Auditor General says how you're treated by CRA depends on where you live and…
Are the feds coming for your lottery winnings?
Reports suggest the Canada Revenue Agency is looking at taxing your poker winnings. Tax expert…
Television
David Rotfleisch interviewed by Andrew Chang, on CBC’s show “About That…capital gains tax”
Canada's capital gains tax increase came into effect on June 25, 2024. Andrew Chang breaks…
“Talking Tax – Segment 3: The tax man is very aware of cryptocurrency: Tax lawyer David Rotfleisch” BNN Bloomberg
David Rotfleisch, founder and senior tax lawyer at Rotfleisch & Samulovitch, goes over tax issues…
“Talking Tax – Segment 2: Tax Tips with David Rotfleisch, managing partner at Rotfleisch & Samulovitch” BNN Bloomberg
David Rotfleisch, managing partner at Rotfleisch & Samulovitch, shares his tax tips with viewers. Watch…
“Talking Tax – Segment 1: Talking Tax with David Rotfleisch, managing partner at Rotfleisch & Samulovitch” BNN Bloomberg
David Rotfleisch, managing partner at Rotfleisch & Samulovitch, answers viewers' questions. Watch this segment by…
Canadian Tax Lawyer Shares Insights on Cryptocurrency Taxation on BNNBloomberg.ca
Canadian tax lawyer David Rotfleisch, founder and senior tax lawyer of Rotfleisch & Samulovitch PC,…
Toronto Tax Lawyer Answers Tax-Related Questions on BNNBloomberg.ca
Toronto tax lawyer David Rotfleisch, founder and senior tax lawyer of Rotfleisch & Samulovitch PC,…
Toronto Tax Expert Shares Tax Tips on BNNBloomberg.ca
Toronto-based tax expert David Rotfleisch, founder and senior tax lawyer at Rotfleisch & Samulovitch PC,…
Canadian Tax Lawyer Featured on CityNews Video Report on CERB Repayments
Canadian tax lawyer David Rotfleisch was featured in a video news report on CityNews ("Self-employed…
Toronto Tax Expert Talks About CERB Repayments in Video Interview on BNNBloomberg.ca
Toronto tax expert David Rotfleisch offered his take on CERB (Canada Emergency Response Benefit) repayments…
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Pro Tip
Tax Audits in Ontario
There are over 350,000 tax audit and review actions conducted by the Canada Revenue Agency on a yearly basis. Around 15,000 of these tax audits deal with “cash only” businesses (i.e. the underground economy). Additionally, an estimated 35,000 are tax shelter audits.
