Tax
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CRA’s collection department & paying tax debts in dispute

By Peter Aprile The Canada Revenue Agency’s (“CRA”) Audit, Objection, Appeals and Collection Departments are separate, but related, departments. The nature of ... Read more

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Woodyard to discuss tax tips for lawyers, clients

Toronto tax litigator Adrienne Woodyard is set to share her insights into tax issues that affect lawyers and their clients at the upcoming Law Society of Upper Canada Solo and ... Read more

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Ponzi tax deduction issue still unresolved

Although a recent Tax Court of Canada case attempted to deal with the question of whether Ponzi scheme losses are deductible, the issue is still not fully resolved, Toronto tax ... Read more

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Advice from tax lawyer crucial before investing in charity shelter

News that the Canada Revenue Agency (CRA) is widening its probe into a number of charity tax shelter schemes highlights the importance of seeking professional tax advice before ... Read more

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Lifetime Capital Gains Exemption – tax lawyer explanation

By David Rotfleisch The Canadian capital gains exemption allows Canadian individual taxpayers to realize tax-free capital gains on the disposition of shares of a Qualified Small ... Read more

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Expertise, empathy, technology keys to better client experience

While speaking engagements and other traditional ways of growing a business are important, so too is harnessing technology to arm clients with better information, Toronto tax ... Read more

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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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