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CRA Delays Under Formal Investigation: Limited Remedies for Taxpayers Facing Administrative Backlogs
Overview: Systemic CRA delays trigger formal investigation Canada’s Taxpayers’ Ombudsperson has initiated a systemic examination into delays at the Canada Revenue Agency (CRA), focusing on prolonged processing timelines and deficiencies…
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CRA Denied Your Business Loss After a Tax Audit? What to Do Immediately to Challenge the Reassessment
Overview: A CRA Tax Audit Denial Can Cost You Tens—or Hundreds—of Thousands A CRA tax audit that denies your business losses can immediately increase your taxable income, eliminate loss carryforwards,…
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Cross-Border Businesses: CRA vs IRS Tax Authority Size, Efficiency, and Tax Enforcement
CRA vs IRS Size Comparison: Understanding the Scale of Tax Administration in Canada and the United States Business leaders operating across borders frequently compare the Canada Revenue Agency (CRA) and…
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How the IRS Uses Artificial Intelligence in U.S. Tax Audits — What American Taxpayers Must Know Now
IRS Artificial Intelligence and Tax Audit Risk: Overview for U.S. Taxpayers Artificial intelligence has moved to the center of how the Internal Revenue Service selects tax returns for audit, detects…
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IRS Voluntary Disclosure Program Gets Major 2026 Update: Key Changes for Taxpayers With Hidden Income, Offshore Accounts
Overview of IRS Voluntary Disclosure Program Changes for 2026 The IRS’s proposed 2026 overhaul of the Voluntary Disclosure Practice (“VDP”) represents one of the most significant changes to U.S. tax…
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Director’s Liability for Taxes: A Canadian Tax Lawyer’s Guide to CRA Rules
Overview: What Directors Need to Know About Personal Liability for Corporate Taxes Corporations are treated as distinct legal persons, separate from their shareholders, directors, and officers. What this means is…
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Canada Child Benefit Eligibility After Separation/Divorce: A Canadian Tax Lawyer Explains Why ‘Protected Person’ Status in Immigration Law Ends, in Mohamed v. The King
Overview – Canada Child Benefit Eligibility, Immigration Status, and the Limits of Judicial Relief In Mohamed v. The King, the Tax Court of Canada considered a difficult and highly sympathetic…
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The Stock Option Buyout Trap: Why a Canadian Tax Lawyer Says Tax Timing Is Everything
An employee stock option buyout is generally a taxable employment benefit, but the precise rule depends on how the buyout is structured. Under subsection 7(1) of the Canadian Income Tax…
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Living Abroad? A Tax Lawyer Explains What the Shakira Tax Case Teaches Americans About Moving Wealth
Shakira Tax Case Overview: Essential Insights on Tax Residence for High-Net-Worth Americans Colombian superstar Shakira has secured an important win against Spanish tax authorities. Spain’s High Court cleared her of…
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How to Beat CRA Alternative Tax Assessments: Insights from a Canadian Tax Lawyer
Overview: The Canada Revenue Agency’s Alternative Tax-Assessment Techniques & How to Beat Them When the Canada Revenue Agency’s tax auditors can’t rely on your official books and records—whether it’s because…
