CRA wins appeal against couple who alleged 'malicious' tax evasion probe
VANCOUVER — The British Columbia Court of Appeal has set aside a $1.7-million damage award to a Vancouver Island couple who a lower court had said were ruined through the “malicious'' actions of the Canada Revenue Agency. Read more
Tax writeoff an option for defunct cryptocurrency exchange users
With recovery efforts proving to be challenging so far, Canadians holding cryptocurrency on an insolvent exchange may be in a position to claim a tax loss, Canadian tax lawyer David J. Rotfleisch tells AdvocateDaily.com. Read more
Qualified tax adviser a key partner for U.S. taxpayers in Canada
While U.S. taxpayers living in Canada might be tempted to hire any preparer to file their tax return south of the border, a qualified U.S. tax adviser can help them navigate this complex and constantly evolving landscape and ensure their personal and business objectives are met, Oakville-based U.S. tax attorney (NY, DC) Alexey Manasuev tells AdvocateDaily.com. Read more
CRA-IRS information sharing has 'no direct effect' for most taxpayers
Although most taxpayers will not be directly affected by the Canada Revenue Agency (CRA)’s move to share millions of banking records with the U.S. over the last five years, there is a risk of audit for those who may not have complied with American reporting requirements, Canadian tax lawyer David J. Rotfleisch tells AdvocateDaily.com. Read more
Paradise Papers audits show CRA cracking down on offshore tax evasion
Reports that the Canada Revenue Agency (CRA) is auditing a number of taxpayers named in the Paradise Papers tax leak confirm just how serious the taxman is about cracking down on offshore tax evasion, Canadian tax lawyer David J. Rotfleisch tells AdvocateDaily.com. Read more
Partnerships need to consider new U.S. tax representative role
With the recent introduction of new partnership audit rules that set out who can represent a business before the IRS on tax matters, now is the time for partnerships — both U.S. and foreign — to act proactively to ensure they comply with the strict requirements of the new role, U.S. tax attorney (NY, DC) Alexey Manasuev tells AdvocateDaily.com. Read more
New CRA tool unlikely to deter tax evaders: Rotfleisch
The Canada Revenue Agency’s (CRA) recent decision to start using the Criminal Code proceeds-of-crime provision to seize the assets of those charged with tax evasion likely has more to do with raising revenues than with general deterrence, Canadian tax lawyer David J. Rotfleisch tells AdvocateDaily.com. Read more
Be aware of continued impact of U.S. tax reform on 2018 returns
While U.S. tax reform had a significant impact on expats and shareholders of foreign corporations last year, it is critical for taxpayers to be aware of the ongoing relevance of these new provisions as they look ahead to their filing for 2018, Oakville-based U.S. tax attorney (NY, DC) Alexey Manasuev tells AdvocateDaily.com. Read more
Case shows possible limits of First Nations business tax exemption
Although First Nations people living on reserves are eligible for a number of tax exemptions , a recent case shows that in the eyes of the taxman, this rule does not necessarily apply to a business on a reserve whose customers are non-Aboriginal, Canadian tax lawyer David J. Rotfleisch tells AdvocateDaily.com. Read more
Report shows CRA stats affecting taxpayer treatment at audit
A newly released report by Canada’s auditor general appears to show that Canada Revenue Agency (CRA) targets may be driving the way in which taxpayers are being treated at audit, Canadian tax lawyer David J. Rotfleisch tells AdvocateDaily.com. Read more
Decision to renounce U.S. citizenship should not be tax-based
For American citizens and Green card holders living in Canada, the overwhelming nature of complying with tax filing requirements may lead some to consider the step of renouncing their citizenship — but, as Oakville-based U.S. tax attorney (NY, DC) Alexey Manasuev tells AdvocateDaily.com , this decision should not be based solely on tax concerns. Read more
The position of executor: from cradle to grave – Part V
By Avi Dahary for AdvocateDaily.com . Personal and Estate Income Tax Read more
Use of AI software in tax cases positive if litigation reduced
News that the government has started a pilot project to use commercial artificial intelligence software in tax cases is a welcome development for taxpayers if it ultimately results in less unnecessary litigation, Canadian tax lawyer David J. Rotfleisch tells AdvocateDaily.com. Read more
IRS OVDP no more! Where do you go from here?
As announced earlier this year , the IRS closed its Offshore Voluntary Disclosure Program (OVDP) in September — a program that started back in 2009 and went through several iterations, with the most recent changes made in June 2014 , says Oakville-based U.S. tax attorney Alexey Manasuev , a principal of U.S. Tax IQ . Read more
Proposed tax changes set to remove uncertainty for charities
Draft tax legislation that proposes to remove restrictions on charities’ non-partisan political activities will act to both clarify the rules and give organizations more scope with respect to their operations, Canadian tax lawyer David J. Rotfleisch tells AdvocateDaily.com . As The Lawyer’s Daily reports, the draft legislation proposes to amend the Income Tax Act (ITA), to implement changes consistent with Recommendation #3 of the Report of the Consultation Panel on the Political Activities of Charities — an expert panel appointed by the National Revenue Minister Diane Lebouthillier in 2016 that provided recommendations based on consultations held with charities. Read more
