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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…
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Is the CRA Easier on You Than the IRS? A Canadian Tax Lawyer Explains Their Different Tactics, Processes
Overview: Understanding CRA vs IRS Enforcement The perception that Internal Revenue Service enforcement is stronger than Canada Revenue Agency enforcement is common among taxpayers and advisors, particularly in cross-border contexts. …
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CRA vs. IRS Audits: What Every Canadian Tax Lawyer Wants You to Know
Overview of CRA Tax Audits and IRS Audit Processes for Cross-Border Taxpayers Cross-border taxpayers, corporations, investors, and high-net-worth individuals increasingly face scrutiny from both the Canada Revenue Agency (CRA) and…
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How to Meet the Very High Bar for Establishing and Maintaining Canadian-Controlled Private Corporation (CCPC) Status, plus Corporate and Tax Implications of Share Transfer
The classification of a corporation as a Canadian-controlled private corporation (CCPC) is one of the most significant tax designations a private enterprise can achieve. This status unlocks a suite of…
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Smith v. The King – Missed the Deadline to Object to a CRA Tax Reassessment? What the Tax Court Requires to Grant an Extension of Time
Introduction – Why Missing a Deadline Is Not the End, But Procedure Is Everything When a taxpayer misses the deadline to file a notice of objection to a CRA tax…
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Gill v. The King -Transferring Property Among Family Members, when You’re in Debt to CRA? That Triggers Secondary Tax Liability (because it Appears to be a Tax Dodge)
Background: Section 160 and Derivative Tax Liability Section 160 of the Income Tax Act (ITA) is one of the most potent collection tools available to the Canada Revenue Agency (CRA).…
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CRA SR&ED Pre-Claim Approval Process (2026): Improved Strategic Tax Planning for SR&ED Tax Credits in Canada with Tax Credit Certainty, Faster Processing
Overview: CRA SR&ED Pre-Claim Approval and Its Impact on Canadian R&D Tax Credits The Scientific Research and Experimental Development (SR&ED) tax incentive program remains Canada’s most significant federal support mechanism…
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International Crypto Fraud Crackdown: How CRA Treats Tax Losses from Crypto Scams in Canada
Overview: Global Crypto Fraud Enforcement and Canadian Tax Consequences for Victims A recent international law enforcement operation has highlighted the growing scale and sophistication of cryptocurrency fraud, while simultaneously raising…
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Federal Court of Appeal Strikes Down CCPC Continuance Planning Under GAAR in Canada v. DAC Investment Holdings Inc: Guidance from Canadian Tax Lawyer
On February 20, 2026, the Federal Court of Appeal (FCA) released its decision in Canada v. DAC Investment Holdings Inc. (DAC), 2026 FCA 35, overturning the Tax Court of Canada’s…
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Closing the Loophole on Indirect Trust Transfers and the 21-Year Deemed Disposition Rule: New Measure in Budget 2025
Overview—The 21-Year Deemed Disposition Rule For Canadian tax planners and trust beneficiaries, the “21-year rule” is a critical milestone. Under the Income Tax Act (ITA), most personal trusts, such as…
