Canada: Tax Authorities

Most published commentary on Canada's Crypto-Asset Reporting Framework explains what CARF is. For a practitioner, that is the easy part and it is not the part that creates professional exposure. The reporting obligation falls on the reporting crypto-asset service provider, not on the accountant or the tax lawyer and not on the client.

The Canada Revenue Agency revoked Speed Skating Canada's registration as a qualified donee for missing a tax filing deadline, despite the organization's claim of timely submission. This case raises critical questions about whether revocation is the most proportionate response when the CRA has discretionary authority and alternative compliance tools at its disposal.

Requests and requirements for information (RFIs) are among the Canada Revenue Agency’s (CRA) most powerful audit tools. Recent legislative proposals would introduce new administrative penalties for non-compliance with RFIs, increasing the consequences for recipients.

If you have signed, or are about to sign, an agreement to buy a newly built home in Ontario, the HST you recover could be anything from nothing to $130,000. The difference usually comes down to a signing date, a price threshold, or whose name is on the purchase agreement, and not to whether you are buying your first home.

When the Canada Revenue Agency overhauled the Voluntary Disclosures Program (VDP) effective October 1, 2025, replacing Information Circular IC00-1R6 with IC00-1R7, it left tax practitioners with a long list of practical questions.

Canada’s tax system is a system of self-reporting. This feature is explicitly stated in subsection 150(1) of the Income Tax Act. This subsection requires taxpayers to file a tax return “without notice or demand for the return, for each taxation year of a taxpayer.”

A bare trust is generally an arrangement in which the trustee holds only legal title to property and acts purely as the beneficiaries’ agent, with no independent discretion over it.

Le gouvernement fédéral propose d'élargir considérablement les incitatifs fiscaux destinés à stimuler l'investissement des entreprises au Canada avec la mégadéduction à la productivité. Cette nouvelle mesure permanente pourrait modifier la façon dont les entreprises évaluent et planifient leurs investissements en équipement, technologies et autres actifs nécessaires à leur croissance.

The Tax Court of Canada decision in Salehi v The King, 2026 TCC 139 [Salehi], is a reminder that GST/HST exposure on a newly built home turns on intention, and that intention is established by conduct rather than by paperwork.