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Articles

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…

Benefits of paperless processing for taxpayers: Lessons for CRA from the IRS

Canadian taxpayers will benefit if the CRA follows the IRS in the paperless processing of…

Are CRA publications clear and easy to understand? Can Canadian taxpayers trust their information?

Canadian tax lawyer and accountant David J Rotfleisch explains why taxpayers should not necessarily trust…

Standards of tax statutes and tax caselaw must be respected in reply from CRA to taxpayers

The Hillcore Financial decision by the Tax Court Of Canada shows the importance of crafting…

Tax settlement in Canadian tax litigation: Challenges for Canadian taxpayers

Canada's courts say a CRA settlement must be principled and not a compromise, explains Canadian…

CRA to introduce new automatic tax filing system as many Canadians miss out on benefits

THE Canada Revenue Agency (CRA) is set to pilot a new automatic tax filing system…

10 fun facts about taxes in Canada

1.  Canada collects more than twice as much personal tax than it does in corporate…

Updated GAAR guidance could boost reporting under expanded mandatory disclosure rules

Toronto tax lawyer David Rotfleisch said advisors and promoters who err on the side of…

Lawyer-client confidentiality may fail to protect end-product tax documents, says FCA

The question, however, is whether legal privilege also applies to a document that implements, or…

Social media influencers must pay fair share of taxes, CRA insists

A social media influencer based in Canada is required to declare all earnings to the…

How to legitimately defer the worst of Canada’s departure tax when becoming a non-resident and moving to another country

The Canadian tax system provides limited taxpayer relief under subsection 220(4.5) of the Income Tax Act by allowing qualifying…

CRA asks Shopify to hand over records for more than 120,000 Canadian businesses to check for tax evasion

The Canada Revenue Agency is demanding six years’ worth of records from Shopify on all…

GST/HST tax fraud is a ‘special operation’ at the Canada Revenue Agency

After reviewing Canada's GST/HST system, this article compares two of the more involved types of…

The case for employee ownership trusts

“There have been heavy lobbying efforts pressing the government to go ahead with what it…

Nine ways to prevent triggering a CRA tax audit

One thing that raises the CRA’s suspicions is when reported income is well below the…

Yes, you should pay the Canada Revenue Agency for day trading in tax-free savings accounts

The court was right last week in ordering an investor to pay the Canada Revenue…

When the CRA reassessed a taxpayer’s tax returns beyond the normal reassessment period

Canadian accountant and tax lawyer David J. Rotfleisch explains how, in Goldhar v The King, a toy salesman successfully appealed a CRA reassessment.   Read more here

Cryptoassets raise questions about foreign property disclosure

In addition, real estate held abroad for personal use — such as a vacation home…

When a tax-free savings account is a business & stripped of tax benefits

While the experienced Canadian tax litigation lawyer for the taxpayer launched many creative and novel…

SR&ED: The CRA cannot use its civil tax audit power to gather information for a criminal investigation

David J Rotfleisch explains why the Federal Court of Appeal ruled in favour of the…

Proposed amendments to GST/HST rules for cryptocurrency mining, part two

The proposed cryptocurrency-mining tax rules contain an exception when a person performs the cryptocurrency-mining activity…

Proposed amendments to GST/HST rules for cryptocurrency mining

The proposed rules will treat cryptocurrency mining as an exempt supply. The cryptocurrency miner will…

The ‘reasonability requirement’ for administrative suspension of EFILE rights

The administrative decision to suspend the rights and privileges of a taxpayer under the EFILE…

Rectification saves taxpayers from adverse tax consequences arising from drafting error

A KPMG tax planning document saved Sleep Country from the consequences of a numerical error,…

Taxpayers cleared to pursue negligence claim against CRA in Myers v. Canada

Where the CRA oversteps boundaries and takes controversial legal positions against a taxpayer, the results…

Tax Court orders CRA to release GAAR committee reports about similarly situated taxpayers

Canadian accountant and tax lawyer David J Rotfleisch explains why the Committee's legal analysis fell…

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

“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…

What Our Clients Say

I’ve used Rotfleisch & Samulovitch for complex tax planning matters over the past few years. I’ve found them to be extremely knowledgeable, professional & effective, and would highly recommend them especially for entrepreneurs and their companies. R&S’ legal tax knowledge are a solid complement to the expertise of a quality accountant.

Mark Barnicutt

Toronto, Tel Aviv

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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.

Get your CRA tax issue solved


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