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When Relying on a Tax Preparer and Ignoring Tax-Return Red Flags Becomes Wilful Blindness: A Canadian Tax Lawyer’s Analysis of Kane v. The King
Contents Overview: When Tax-Return Red Flags Can Lead to a CRA Gross Negligence Penalty Background: How a Fictitious Business Loss Led to a CRA Tax Penalty in Kane When Does…
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Bare Trust Tax in Canada: Beneficiary Changes, Trustee Changes and Death Dispositions
What are the Tax Rules for Bare Trusts in Canada? Plus, Trustee Changes, Beneficiary Additions & ‘Deemed Disposition’ at Fair Market Value at Death Overview A bare trust is generally…
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Tax Court Shuts Down Foreign Continuance Loophole: CRA can Tax a Canadian-Controlled Private Corporation (CCPC): Lessons from Somerset Limited v The King, 2026 TCC 123
Contents Overview – Why the Offshore Continuance Failed In Somerset Limited v The King, 2026 TCC 123, the Tax Court of Canada considered whether a Canadian private corporation could reduce…
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How the Principal Residence Tax Exemption Works in Canada: Eligibility Requirements, Property Flipping Rules, and Common CRA Tax Traps
The principal residence exemption can eliminate some or all of the tax payable on the sale of a qualifying home, but the exemption is subject to detailed statutory requirements and…
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CRA Disability Tax Credit: How Type 1 Diabetics Can Secure Retroactive Refunds
How the Disability Tax Credit Applies to Type 1 Diabetes in Canada For years, Canadians living with Type 1 diabetes faced an uphill battle to obtain the federal Disability Tax…
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King Charles Taxation and Canadian Comparisons: Voluntary Compliance, Crown Privilege, and Tax Transparency
King Charles Tax Disclosure, Canadian Crown Exemptions, and Voluntary Tax Compliance: An Overview In a development described as historically unprecedented, King Charles III has announced that he will publicly disclose…
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Why Tax Lawyers Have a Secret Weapon Against the CRA & Accountants Don’t: Solicitor-Client Privilege and the Limits of CRA Audit Powers in Minister of National Revenue v. KPMG Canada LLP
Overview: Accountant Privilege, CRA Compliance Orders, and the Income Tax Act The Federal Court’s June 12, 2026 decision in Minister of National Revenue v KPMG Canada LLP, T-139-26, is a…
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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…
