Worldwide: Income Tax

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

CRA Home "Builder" Audits Using MLS Data!

As we have previously written here, the Canada Revenue Agency ("CRA") has significantly expanded its audit activity in the residential real estate sector – particularly targeting homeowners...

MK

Millar Kreklewetz

Cineplex: A Payment To Cease Operations Was Deductible

In Cineplex Inc. v The King, the Tax Court of Canada confirmed that a payment made to cease business operations was a deductible business expense...

MT

McCarthy Tétrault LLP

Accepting Money From A Spouse With Tax Problems Can Give You A Bigger Problem With CRA: Panneton v. The King (2024 TCC 24)

The decision in Panneton v. The King is an important reminder of how strictly Canadian courts apply section 160 of the Income Tax Act.

RS

Rotfleisch & Samulovitch P.C.

Does Your Remote Employee's Home Office Create A Permanent Establishment?

The Organisation for Economic Co-operation and Development (the OECD) recently published an update to its Model Tax Convention on Income and on Capital...

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Dentons Canada LLP

Director Compensation For Charities In Canada

GW

Gowling WLG

Canadian Federal Government Releases Hybrid Mismatch And Other Draft Tax Amendments

OH

Osler, Hoskin & Harcourt LLP

Coram Deo Foundation v MNR (2026 BCSC): When An Interim Injunction Plus Charitable Status Is Revoked And Confront Constitutional Limits On CRA's Authority

RS

Rotfleisch & Samulovitch P.C.

How Canadian Crypto Traders And Investors Should Handle Losses On Obsolete Crypto Inventory On Their Taxes

RS

Rotfleisch & Samulovitch P.C.

CRA Introduces Software-Specific Controls For EFILE Accounts, A Safety Feature, Starting In 2026

RS

Rotfleisch & Samulovitch P.C.

When CRA Employees Misbehave And Make Mistakes Against Canadian Taxpayers

RS

Rotfleisch & Samulovitch P.C.

Tolley v. The King – When Taxpayer Relief, CPP Limitation Periods, And Procedural Finality Abandon Fairness Without A Remedy

RS

Rotfleisch & Samulovitch P.C.

The 40-Kilometre Rule Revisited: How De Kruyff v The King Clarifies Moving Expense Tax Deductions In The Age Of Google Maps And Traffic Congestion

RS

Rotfleisch & Samulovitch P.C.

Foreign Assets Under The Microscope: Navigating Today's T1135 Audit Push

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Borden Ladner Gervais LLP

Cash Today Or Equity Tomorrow? The Real Tax Cost Of Bonuses vs. Stock Options

Canada Employment

DS

Devry Smith Frank LLP

Court Finds Employee Rightfully Dismissed After Publishing Social Media Post About His Employer

Canada Employment

C

Cassels

Canada's 2025 Federal Budget: Critical Changes To Cryptocurrency Taxation Investors, Traders, And Miners Need To Know

RS

Rotfleisch & Samulovitch P.C.

Hiding In The Shadows: The Perils Of Shadow AI On Your Organization

Canada Technology

BJ

Bennett Jones LLP

11 Tax Changes To The Income Tax Act (ITA) In 2026 And Beyond That Canadian Taxpayers, Canadian Businesses Need To Know About

RS

Rotfleisch & Samulovitch P.C.

How To Master The 24-Month Holding Period Requirement For QSBC Shares And Lifetime Capital Gains Exemption In Canada

RS

Rotfleisch & Samulovitch P.C.

What To Do When You Receive A Notice Of Non-Compliance: Advanced Strategies To Comply With A Canadian Tax Audit, Fixing Honest Tax Mistakes, Resolving CRA Audits, And Canadian Crypto Tax Challenges While Avoiding Costly CRA Penalties

In the strict world of Canadian tax audit compliance, entrepreneurs, professionals, investors, accountants, and crypto investors often need to fix Canadian tax errors quickly. This helps avoid big penalties, long delays, and business problems.

RS

Rotfleisch & Samulovitch P.C.

What Businesses Need To Know About Expanding Minister Of National Revenue Powers During Reassessments Under Income Tax Act, Subsection 152(9) – Perspective From Canadian Tax Lawyer

Canadian tax law evolves constantly, with Tax Court of Canada rulings playing a pivotal role in clarifying the Minister of National Revenue's authority over reassessments.

RS

Rotfleisch & Samulovitch P.C.

Excess Capital Dividends And The Whopping 60 Percent Penalty Tax: A Canadian Tax Lawyer's Guide To Prevent Capital Dividend Account Pitfalls In Tax Planning

Capital dividends are among the most powerful dividend tax planning tools available to Canadian-controlled private corporations. When properly structured, a capital dividend allows a corporation to distribute tax-free amounts to shareholders without triggering personal income tax.

RS

Rotfleisch & Samulovitch P.C.

Martin v The King 2024 TCC 153: Canadian Tax Treatment Of Retirement Compensation Arrangements (RCAs) For Non-Resident Professional Athletes – Cross-Border Tax Planning Insights Under Canada-US Tax Treaty

The Tax Court of Canada decision in Martin v The King, 2024 TCC 153, delivers important guidance on the Canadian tax treatment of Retirement Compensation Arrangements (RCAs) for non-resident professional athletes and other high-income earners with cross-border income.

RS

Rotfleisch & Samulovitch P.C.

How To Properly Claim Employment Insurance Repayments And Protect Your Tax Relief: Lessons From Dandees v. The King (2025 TCC 171)

RS

Rotfleisch & Samulovitch P.C.

OECD Releases "Side-by-Side" Administrative Guidance Package

MT

McCarthy Tétrault LLP

Quatre mesures touchant les organismes de bienfaisance à surveiller en 2026. Deux d'entre elles sont déjà en cours!

Canada Commercial

MT

Miller Thomson LLP

Be Very Afraid: The Canada Revenue Agency (CRA) Has Impressive Powers To Enforce Collection, Plus Penalties And Interest For Non-Compliance

RS

Rotfleisch & Samulovitch P.C.

How A CRA Tax Audit That Uses Bank Deposit Analysis Affects Tax Reassessments In Canadian Tax Litigation: Comparing Premier Fasteners Inc. v The King And Hickman Motors Ltd. v Canada

RS

Rotfleisch & Samulovitch P.C.

Federal Court Of Appeal Reaffirms That Tax Efficiency Alone Does Not Equate To Abuse Under GAAR: Canada v. Quebecor Inc., 2025 FCA 207

RS

Rotfleisch & Samulovitch P.C.

How To Ensure You're Compliant With The Spot Rate Requirement Under Section 261(1) Of The Income Tax Act

RS

Rotfleisch & Samulovitch P.C.

Cryptocurrency Tax Enforcement Measures In The U.K. And Canada, Compared By A Crypto Tax Lawyer

RS

Rotfleisch & Samulovitch P.C.

New Rules Replace The GILTI — Applicable 2026

A

Altro LLP

COVID-19 Benefit Repayments Surpass $10 Billion: Implications For Canadian Taxpayers And Businesses, Plus How To Handle Overpayment Claims Or Ineligibility Claims By CRA

RS

Rotfleisch & Samulovitch P.C.

What To Do When You Receive A Notice Of Non-Compliance: Advanced Strategies To Comply With A Canadian Tax Audit, Fixing Honest Tax Mistakes, Resolving CRA Audits, And Canadian Crypto Tax Challenges While Avoiding Costly CRA Penalties

In the strict world of Canadian tax audit compliance, entrepreneurs, professionals, investors, accountants, and crypto investors often need to fix Canadian tax errors quickly. This helps avoid big penalties, long delays, and business problems.

RS

Rotfleisch & Samulovitch P.C.

What Businesses Need To Know About Expanding Minister Of National Revenue Powers During Reassessments Under Income Tax Act, Subsection 152(9) – Perspective From Canadian Tax Lawyer

Canadian tax law evolves constantly, with Tax Court of Canada rulings playing a pivotal role in clarifying the Minister of National Revenue's authority over reassessments.

RS

Rotfleisch & Samulovitch P.C.

Excess Capital Dividends And The Whopping 60 Percent Penalty Tax: A Canadian Tax Lawyer's Guide To Prevent Capital Dividend Account Pitfalls In Tax Planning

Capital dividends are among the most powerful dividend tax planning tools available to Canadian-controlled private corporations. When properly structured, a capital dividend allows a corporation to distribute tax-free amounts to shareholders without triggering personal income tax.

RS

Rotfleisch & Samulovitch P.C.

COVID-19 Benefit Repayments Surpass $10 Billion: Implications For Canadian Taxpayers And Businesses, Plus How To Handle Overpayment Claims Or Ineligibility Claims By CRA

The Canada Revenue Agency's drive to recover outstanding amounts from CRA COVID-19 benefit programs has now identified more than $10 billion in repayments due, marking a significant chapter in Canada's fiscal response to the pandemic.

RS

Rotfleisch & Samulovitch P.C.

Net-Worth Assessments, Shareholder Benefits, And Statute-Barred Years: Lessons From Afdon Contracting Ltd. v. The King 2025 TCC 175

RS

Rotfleisch & Samulovitch P.C.

Excess Capital Dividends And The Whopping 60 Percent Penalty Tax: A Canadian Tax Lawyer's Guide To Prevent Capital Dividend Account Pitfalls In Tax Planning

Capital dividends are among the most powerful dividend tax planning tools available to Canadian-controlled private corporations. When properly structured, a capital dividend allows a corporation to distribute tax-free amounts to shareholders without triggering personal income tax.

RS

Rotfleisch & Samulovitch P.C.

A Canadian Tax Audit Compared With A Criminal Investigation: Important Differences And Legal Protections For Taxpayers In Gravel v. Agence Du Revenu Du Québec

As an experienced Canadian tax lawyer specializing in tax audits and investigations, I often advise clients on the critical distinctions between tax audits and criminal investigations under Canadian tax legislation, whether conducted by the Canada Revenue Agency (CRA) or Revenu Québec.

RS

Rotfleisch & Samulovitch P.C.

Canadian Tax Litigation Insights: How The Jennings-Clyde (Vivatas, Inc.) Decision Protects Canadian Taxpayers' Rights In Federal Court Of Appeal

The recent Federal Court of Appeal ruling in Jennings-Clyde v. Canada (Attorney General), 2025 FCA 225, underscores the critical need for administrative transparency when the Canada Revenue Agency (CRA) exercises discretion in taxpayer relief matters.

RS

Rotfleisch & Samulovitch P.C.

Adjusted Cost Basis Traps In Corporate Life Insurance Planning: How To Avoid Nasty Capital Dividend Account Surprises

In Canadian corporate tax planning, few concepts create as much confusion—or as much unexpected tax exposure—as the adjusted cost basis of a corporate-owned life insurance policy.

RS

Rotfleisch & Samulovitch P.C.

Better Corporate Dividend Tax Planning For Business Owners From A Canadian Tax Lawyer

RS

Rotfleisch & Samulovitch P.C.

How Canadian Corporations Can Make Better Strategic Decisions With Life Insurance Proceeds And Capital Dividend Account Planning

RS

Rotfleisch & Samulovitch P.C.

When You're In Cryptocurrency Tax Litigation With CRA Trial Strategy (Part V): Evidentiary Burden, Expert Evidence, And Credibility At The Tax Court Of Canada

RS

Rotfleisch & Samulovitch P.C.

Jennings-Clyde v. Canada (Attorney General), 2025 FCA 225 – When The CRA Denies Taxpayer Relief, It Must Explain Clear Reasons Why

RS

Rotfleisch & Samulovitch P.C.

Removing The T4A Moratorium A Major Move Against Driver Inc.

Canada Transport

MA

MLT Aikins LLP

Amicarelli v The King: How Cryptocurrency Exchange Losses Are Treated For Tax Purposes Under Canadian Cryptocurrency Tax Laws

RS

Rotfleisch & Samulovitch P.C.

CRA Cryptocurrency Tax Litigation Business Income vs Capital Gains (Part IV): Including CRA Tax Audits, And Tax Court Appeals

RS

Rotfleisch & Samulovitch P.C.

When An Oral CRA Refusal Becomes A Reviewable Administrative Decision: Hillcore Financial Corporation v Attorney General Of Canada

RS

Rotfleisch & Samulovitch P.C.

Tax Consequences Of A Salary Deferral Arrangement (SDA) In Canada: How It Works, Plus Exceptions

RS

Rotfleisch & Samulovitch P.C.

Canadian Students Studying Abroad Beware: Why "Tuition Paid" Does Not Mean "Anything You Paid This Year" - Ojaide v. The King (2025 TCC 180)

RS

Rotfleisch & Samulovitch P.C.

Everything You Need To Know About Cryptocurrency Taxation In Canada: Capital Gains On Crypto And Business Income Strategies

RS

Rotfleisch & Samulovitch P.C.

Critical Changes In Revenu Québec's Voluntary Disclosure Program And Comparison To Federal CRA Rules For Canadian Taxpayers

RS

Rotfleisch & Samulovitch P.C.

Canada's Clean Economy Investment Tax Credits: Key Updates And Practical Insights

GW

Gowling WLG

Powering The Cloud: How Alberta Is Reshaping Its Electricity System For Data Centres

GW

Gowling WLG

Case Comment: HMK v. Quebecor Inc. – Federal Court Of Appeal Sides With Taxpayer, Rejects GAAR Challenge To Using Strategy Of Business Losses

RS

Rotfleisch & Samulovitch P.C.

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Highlighted Content

What To Do When You Receive A Notice Of Non-Compliance: Advanced Strategies To Comply With A Canadian Tax Audit, Fixing Honest Tax Mistakes, Resolving CRA Audits, And Canadian Crypto Tax Challenges While Avoiding Costly CRA Penalties

RS

Rotfleisch & Samulovitch P.C.

What Businesses Need To Know About Expanding Minister Of National Revenue Powers During Reassessments Under Income Tax Act, Subsection 152(9) – Perspective From Canadian Tax Lawyer

RS

Rotfleisch & Samulovitch P.C.

Excess Capital Dividends And The Whopping 60 Percent Penalty Tax: A Canadian Tax Lawyer's Guide To Prevent Capital Dividend Account Pitfalls In Tax Planning

RS

Rotfleisch & Samulovitch P.C.

A Canadian Tax Audit Compared With A Criminal Investigation: Important Differences And Legal Protections For Taxpayers In Gravel v. Agence Du Revenu Du Québec

RS

Rotfleisch & Samulovitch P.C.

Everything You Need To Know About Cryptocurrency Taxation In Canada: Capital Gains On Crypto And Business Income Strategies

RS

Rotfleisch & Samulovitch P.C.

Canada's 2025 Federal Budget: Critical Changes To Cryptocurrency Taxation Investors, Traders, And Miners Need To Know

RS

Rotfleisch & Samulovitch P.C.

A Guide To Canadian Corporate Dividend Tax Strategy

RS

Rotfleisch & Samulovitch P.C.

Crypto Tax Trap: Financial Products, Services Offered By US-Based Family Offices And Crypto Asset Management Firms May Prove Unworkable For Taxes Due To CRA For Canadian Cryptocurrency Investors

RS

Rotfleisch & Samulovitch P.C.

Blake v. Ahmed (2025 BCCA 384) – The Court Of Appeal Reaffirms Limits On Taxpayer Claims And Pseudo-Legal Arguments

RS

Rotfleisch & Samulovitch P.C.

Canadian Taxpayers: Here Are The Top 20 Tax Changes For 2025 That You Must Know

RS

Rotfleisch & Samulovitch P.C.

Latest Videos

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2022 Financial Reporting & Tax Updates (Video)

CM

Crowe MacKay LLP

5 Key Takeaways From The Economic Recovery Plan Discussion With Minister Of Jobs, Economy And Innovation, Doug Schweitzer (Video)

MT

McCarthy Tétrault LLP

2021 Federal Budget – Spend, Spend, Spend (Part Deux) With Some Interesting Tax Measures (Video)

MP

Moodys Private Client Law LLP

On-Demand Webinar | Overview Of Essential Services In Alberta And Restrictions To Non-Essential Businesses (Video)

GW

Gowling WLG

Federal Budget 2018: What Would You Like To See? (Video)

CS

Crowe Soberman LLP

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