Articles
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…
What you need to know about new RRSP reporting rules
David Rotfleisch, a tax lawyer with Rotfleisch & Samulovitch P.C. in Toronto, was recently interviewed…
Why I have a Bearded Dragon and a Bichon Frisé on my website
That headline struck you as either odd, eccentric, mildly amusing, or at least quirky. Let…
Preston Family Trust II v The Queen: Assumptions of facts in replies to a notice of appeal
Just the facts, ma'am: David J. Rotfleisch explains why the Tax Court of Canada would…
Canada: Oddi V CRA: Guidance From A Canadian Tax Lawyer Regarding CRA’s Collection Misconduct – Rotfleisch & Samulovitch P.C.
In Oddi v CRA, Mr. Alberta Oddi operated an illegal marijuana growing operation on a…
New proposed mandatory tax planning reporting obligations under the Canadian Income Tax Act
Amendments to the new rules were made in August 2022 and are likely to become…
Court rules employers must include electronic tips under pensionable earnings
David Rotfleisch, founder of tax boutique Rotfleisch & Samulovitch Professional Corp., who wasn’t involved in…
Barrs v The Queen: Taxpayer relief under S.220(3.1)
Canadian accountant and tax lawyer David J Rotfleisch on a Federal Court of Appeal case…
Court rules employers must include electronic tips under pensionable earnings
David Rotfleisch, founder of tax boutique Rotfleisch & Samulovitch Professional Corp., who wasn’t involved in…
Woman mistakenly declared dead by Service Canada for almost a year demands answers
David Rotfleisch, a Toronto tax lawyer, did not work on Shum's case specifically, but he…
David Rotfleisch on Canadian Tax Residence: Are Significant Residential Bonds Less Essential for Canadian Immigrants than for Canadian Emigrants in the Case of Tax Residence in Canada?
The amount of income that can be taxed by Canada depends on a person's status…
MNR v Zhao: CRA collection action when there are reasonable grounds for delay
Canadian accountant and tax lawyer David J Rotfleisch on the Canada Revenue Agency's successful jeopardy order in…
Canadian Tax Amnesty – Reviews by Real Customers – TrustAnalytica
Voluntary Disclosure Program (also known as Canadian Tax Amnesty) allows Canadian taxpayers who have not filed…
Tax pipeline planning: A Canadian tax lawyer’s guide and case study
Canadian accountant and tax lawyer David J Rotfleisch on extracting value from a business to an…
FCA overturns Tax Court’s decision because the CRA’s evidence was exclusively about the …
Canadian tax lawyer and accountant David J. Rotfleisch on the Khanna v The Queen decision by the…
Important tax developments in commercial arena
With the international and domestic commercial landscape changing so rapidly of late, it’s perhaps no…
Important tax developments in commercial arena
David Rotfleisch of Toronto tax boutique Rotfleisch & Samulovitch Professional Corporation downplays the significance of…
The Queen v Paletta – The legal test for business income – Canadian Accountant
Tax lawyer and accountant David J. Rotfleisch on the CRA's successful appeal of a Tax Court of…
Afghan employees of Canada’s Kabul embassy say CRA taxing income earned in Afghanistan
“I find this quite bewildering … I’m amazed at this result,” said Rotfleisch. “I can’t…
Transferring cryptocurrency to a bare trustee or holding cryptocurrency as a bare trustee
Tax lawyer and accountant David Rotfleisch on Canadian cryptocurrency tax planning through the use of bare trusts.…
Tax facts resource provides info which is ‘important and not readily accessible,’ lawyer says
A Toronto-based tax lawyer has released an online resource aimed at providing up-to-date information about…
How to dispute a tax decision
The single biggest tax mistake David Rotfleisch sees Canadians make is waiting too long to…
Rotfleisch & Samulovitch P.C. Launches LinkedIn Company Page
Clients and possible prospects of Rotfleisch & Samulovitch Professional Corporation and the general public can…
Corporate taxes can be good for shareholders: Why some actually want their companies to pay tax
Accounting Professor Andrew Bauer explained that in the integrated tax system in Canada, corporate and…
Inside a little-known tax ‘loophole’ experts say is helping rich Canadians avoid millions in taxes
David Rotfleisch, a tax lawyer with Rotfleisch & Samulovitch P.C. in Toronto, commented on how…
Canadian Tax Lawyer Quoted in Article on Death Tax and Deemed Dispositions
David Rotfleisch, a tax lawyer with Rotfleisch & Samulovitch P.C. in Toronto, shared his thoughts…
Canadian Tax Lawyer Explains Relationship Between Deemed Disposition and Double Taxation
David Rotfleisch, a tax lawyer with Rotfleisch & Samulovitch P.C. in Toronto, explained why all…
Canadian Tax Lawyer Shares Thoughts on How ‘Carousel Fraud’ Can Hurt Innocent Businesses.
David Rotfleisch, a tax lawyer with Rotfleisch & Samulovitch P.C. in Toronto, was featured and…
Toronto Tax Lawyer Shares Perspective on Minutes of Settlement vs. Consent to Judgment
As many Canadian taxpayers face possible CRA tax disputes, David Rotfleisch, a tax lawyer with…
Canadian Tax Lawyer Analyzes the Expanded Canada Worker Lockdown Benefit
As more and more people lose their jobs due to the pandemic, the Canadian government…
Rotfleisch & Samulovitch P.C. Launches LinkedIn Company Page
Clients and possible prospects of Rotfleisch & Samulovitch Professional Corporation and the general public can…
Canadian Tax Lawyer Explains Why a Homebuyer Was Denied the New Housing Rebate by the Tax Court of Canada
David Rotfleisch, a tax lawyer with Rotfleisch & Samulovitch P.C. in Toronto, shared his thoughts…
Canadian Tax Lawyer Explains Why a Homebuyer Was Denied the New Housing Rebate by the Tax Court of Canada
David Rotfleisch, a tax lawyer with Rotfleisch & Samulovitch P.C. in Toronto, shared his thoughts…
Share transfers to executives, employees are income not capital gains: appeal court
David Rotfleisch, a tax lawyer with Rotfleisch & Samulovitch P.C. in Toronto, explained why executives…
Tax Court rules that gift of shares of a private corporation to a foundation was ineligible for a charitable tax credit
David Rotfleisch, a tax lawyer with Rotfleisch & Samulovitch P.C. in Toronto, shared his thoughts…
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 BarnicuttToronto, Tel Aviv
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.
