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The Evolution of Administrative Tax Penalties in Canada and Why it Matters to Canadians: From Guindon to Bozzer and Beyond
Introduction: CRA Administrative Penalties and the Canadian Courts Administrative tax penalties have become one of the Canada Revenue Agency’s (CRA) most powerful enforcement tools. Since the Supreme Court of Canada’s…
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Guindon v Canada (2015 SCC 41): Landmark Supreme Court Tax Case
Introduction The first half of 2015 was marked by a defining moment in Canadian tax law: the Supreme Court of Canada’s ruling in Guindon v Canada (2015 SCC 41). This…
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How American Taxpayers Can Resolve Undeclared Income and Avoid Tax Penalties: Many U.S. States Now Offer Tax Amnesty Programs
Introduction: Understanding 2025 State Tax Amnesty Programs Tax amnesty programs have become an increasingly common tool for U.S. states to collect unpaid taxes. These programs offer taxpayers the chance to…
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Agreements Must Be in Writing: Lessons from Hutchings v. The King (2025 TCC 108) on COVID-19 Rent Subsidies
Canada Emergency Rent Subsidy (CERS) and the Importance of Written Agreements The COVID-19 pandemic forced thousands of Canadian businesses to close temporarily, putting immense pressure on small business owners. To…
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Couture v Canada (Revenue Agency): Canadian tax lawyer Explains How Not to Conduct a Judicial Review
Federal Court Dismisses CRA Judicial Review In Couture v Canada (Revenue Agency), 2024 FC 1283, the Federal Court dismissed a taxpayer’s judicial review application relating to the Canada Recovery Benefit…
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A Canadian Crypto Tax Lawyer Analyzes the Terra USD Collapse and Kwon Do-Hyung’s Guilty Plea to Wire Fraud from Crypto Crash
Introduction: The Collapse of the Terra Ecosystem in May 2022 Wiped Out $50 Billion USD in Valuation in Three Days. The collapse of the Terra ecosystem in May 2022 remains…
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Cross-Border Tax Lawyer on Trump’s ‘One Big Beautiful Bill’ (OBBB): Key Impacts for Canadians
Introduction: A Canadian Tax Lawyer’s Guide to the OBBB The United States’ One Big Beautiful Bill (OBBB), signed into law in 2025, represents a sweeping tax overhaul for individuals and…
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U.S. Crypto Tax Lawyer’s Review: Terra USD Collapse, Do Kwon’s Guilty Plea for Fraud for $40B, and Tax Implications
Introduction: The Terra Collapse and Its Fallout The collapse of Terra Luna in 2022 remains one of the most notorious events in cryptocurrency history. Billions in investor wealth were wiped…
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Key Corporate Tax Changes in the New U.S. Tax Bill: Implications for Business in 2025
Introduction Congress’s recent tax bill not only reshapes the landscape for individuals but also introduces sweeping changes for businesses. For corporations, the legislation reflects a balance between promoting domestic investment…
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C Corporation vs. Pass-Through Entity: Which Structure is Most Tax-Efficient for US Businesses?
Introduction Choosing the right business entity is one of the most important tax and strategic decisions for US entrepreneurs. The recent tax law changes, including the OBBB provisions, make it…
