Tax

Solicitor-client privilege does not extend to accountant files

Although communications between tax lawyers and their clients are subject to solicitor-client privilege, the files of accountants can be seized by the taxman and form part of a tax evasion prosecution — including notes of meetings or conversations, says Canadian tax lawyer David J. Rotfleisch , the Financial Post reports. Read more

Woodyard to chair Law Society 'Tax Primer for Litigators' program

Toronto tax litigator Adrienne Woodyard will chair the upcoming ‘Tax Primer for Litigators’ continuing professional development program, presented by the Law Society of Upper Canada. Read more

Answering complex tax queries requires in-depth experience

It is unsurprising that a recent evaluation showed some small businesses have been receiving inadequate information from the Canada Revenue Agency (CRA) call centre, as it takes years of experience to be able to properly answer questions on Canada's complex tax statutes, Canadian tax lawyer David J. Rotfleisch tells AdvocateDaily.com. Read more

Canada's role as global tax haven 'surprising': Rotfleisch

Reports that Canada is considered to be a useful player in international tax evasion is just the latest surprising revelation from the Panama Papers information leak, Canadian tax lawyer David J. Rotfleisch tells AdvocateDaily.com. Read more

Top driver's case demonstrates taxman's collection powers

Reports claim that Revenue Quebec may be pursuing former world champion Formula One racer Jacques Villeneuve for $1.7 million in unpaid taxes — and in cases like this, the taxman has the right to lien assets without a court order, Canadian tax lawyer David J. Rotfleisch tells AdvocateDaily.com. Read more

The position of executor: from cradle to grave

By Avi Dahary . Part I – An introduction to the position Read more

Tax record 'snooping' undermines confidence in system

Although the privacy of tax records is guaranteed by law, recent reports that claim the Canada Revenue Agency (CRA) was unable to prevent several employees from improperly accessing files undermines taxpayers' confidence in the integrity of the system, Canadian tax lawyer David J. Rotfleisch tells AdvocateDaily.com. Read more

Expect audit letters following CRA review of funds transfers

As part of its crackdown on unreported offshore income and assets, the Canada Revenue Agency (CRA) is set to ramp up its focus on electronic funds transfers to certain jurisdictions — and as a result, a number of Canadian taxpayers should expect to receive an audit letter in the coming year, Toronto tax litigation lawyer David J. Rotfleisch tells AdvocateDaily.com. Read more

Detail, documentation critical to taxpayer relief application

Taxpayer relief applications are one way in which individuals can seek to have the Canada Revenue Agency (CRA) waive or cancel penalties or interest — but when filing a request, there are a number of tips taxpayers should keep in mind to ensure the greatest chance of success, Toronto tax litigator Adrienne Woodyard tells AdvocateDaily. com . Read more

Consider options ahead of 2017 changes to taxation of goodwill

With changes related to the income tax treatment of goodwill set to come into force on Jan. 1, any business owner thinking about selling should consider a restructuring plan that will allow them to take advantage of tax savings offered under the old rules, Toronto tax litigation lawyer David J. Rotfleisch tells AdvocateDaily.com. Read more

CRA takes too long to resolve tax objections, says audit

OTTAWA — The federal government takes months — sometimes years — to make decisions, costing Canadians time and money when it comes to resolving tax disputes, the federal auditor general says. Read more

Days of bank secrecy for offshore accounts 'long gone'

In the wake of the 'Panama Papers' data leak, there has been a concerted international effort to catch offshore tax evaders — which taxpayers should take as a clear sign that the era of secrecy is over for these types of accounts, Toronto tax litigation lawyer David J. Rotfleisch tells AdvocateDaily.com. Read more

'Unconscionable' to tax income without allowing expenses, losses

Although the significant loss Donald Trump reportedly declared on his 1995 income tax return may be partly the result of government loopholes, the ability to carry that loss forward is a basic requirement of tax equity and is far from unfair, Toronto tax litigation lawyer David J. Rotfleisch writes in The Globe and Mail . Read more

Sending condo sellers for tax advice a prudent move

In some Canadian markets, the practise of buying prebuilt condos and flipping them once completed has been a profitable activity — however, as Toronto tax litigation lawyer David J. Rotfleisch writes in Lawyers Weekly , real estate lawyers acting for sellers should be recommending these clients seek tax advice. Read more