Tax
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CRA cuts off electronic access over security concerns

OTTAWA - A major international security concern has forced the shutdown of electronic filing services at the Canada Revenue Agency, and there are concerns the problem could ... Read more

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Appeal to have tax implications for R&D-focused firms

R&D-focused companies are anxiously awaiting more guidance from the courts as to whether they can claim tax credits while also receiving government assistance, says Toronto tax ... Read more

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Tax quote of the day: tax litigation is different

By Peter Aprile We explain to new clients that tax litigation is different, in part, because the Canada Revenue Agency (“CRA”) is a very unique type of litigant. ... Read more

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Donation returns cannot be held in abeyance by CRA

By David J. Rotfleisch In Ficek v. the Attorney General for Canada , 2013 FC 502 the taxpayer successfully compelled the Canada Revenue Agency (CRA) to issue a notice of ... Read more

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Tax Court clarifies trust attribution rule

A recent Tax Court of Canada ruling highlights the need for tax practitioners to analyze how a transfer of property to a trust will either invoke or not invoke subsection 75(2) of ... Read more

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Era of secret offshore bank accounts may be ending

Although the Canada Revenue Agency (CRA) is not likely to start devoting as many resources to finding unreported offshore income as its counterpart in the U.S., it is clear that ... Read more

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Voluntary disclosure an option for unreported offshore income

Although the Canada Revenue Agency (CRA) has a new whistleblower program aimed at combating international tax evasion, taxpayers with unreported offshore income still have the ... Read more

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Legal fee tax deduction depends on connectivity

Two recent Tax Court of Canada decisions provide important insight into the role that connectivity analysis plays when courts are looking to determine the deductibility of legal ... Read more

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Tax Court should go further when awarding costs

Although a recent Tax Court of Canada decision shows a continued trend towards higher costs awards, it also represents a missed opportunity to award full costs in a case where a ... Read more

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Tax lawyer's advice key when entering into tax-based deals

A recent case that has left thousands of unsuspecting taxpayers facing steep penalties after they became involved in a questionable tax scheme highlights the importance of ... Read more

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CRA taking proactive approach in search for offshore accounts

Following news that a number of Swiss banks have signed up to a U.S. Internal Revenue Service (IRS) program to disclose information about U.S. account holders, Toronto ... Read more

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Tax deal with U.S. opens new doors for CRA

OTTAWA – A new deal with the United States over an American law aimed at rooting out tax cheats north of the border will ensure that Canadian financial institutions ... Read more

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CRA income estimate may merit challenge

The Canada Revenue Agency (CRA) may be zeroing in on taxpayers working in industries that have the potential for unreported earnings, but the software the agency uses to estimate ... Read more

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Dealing with CRA letter requires three-step process

The Canada Revenue Agency (CRA) recently kicked off its fifth annual letter campaign aimed at promoting compliance and, for those who are contacted,  it is essential to ... Read more

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De-taxers reconsidering stance have options

Paying taxes may be considered unconstitutional in the “de-tax” movement, but for those having second thoughts about their choice not to file, there are ways to remedy their ... Read more

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Non-filing, tax evasion charges may result in jail time

While failing to file a tax return differs from tax evasion, both charges could potentially result in a jail sentence, says Toronto tax litigation lawyer  David J. Rotfleisch . ... Read more

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Unreported offshore income in focus as CRA program gears up

A federal program that will reward whistleblowers for reporting international tax evasion is set to ramp up, and Canadians with unreported offshore income are advised to take ... Read more

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Offshore tax haven crackdown extends to Israel

News that Israel is planning to provide banking information to foreign tax enforcement authorities is not surprising, as it is similar to many other countries’ aggressive push for ... Read more

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Travelling nurse expenses face CRA scrutiny

The Canada Revenue Agency is taking a close look at the expenses incurred by travelling nurses, even though they are entitled to business-related claims, says Toronto tax lawyer ... Read more

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New CRA tools may mean more tax haven proceedings

Although the Canada Revenue Agency has reportedly struggled to deal with the number of cases involving offshore tax havens, recent moves to expand the CRA’s toolkit will ... Read more

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