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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…
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CRA May Apply 2025 Permanent Establishment OECD Rules to Canada: Remote Work, Authority to Bind, Treaty Interpretation & Interprovincial Tax Risk
Introduction: Permanent Establishment Canada, Remote Work, and OECD Influence on Courts Permanent establishment Canada analysis has become increasingly complex due to the OECD’s 2025 remote work guidance. Remote work permanent…
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Canada’s Anti-Deferral Regime and the FAPI Rules: When Offshore Trust Structures Trigger More Tax
Overview – Canada’s Approach to Offshore Income and Tax Deferral Canadian income tax law does not prohibit Canadian residents from using offshore entities or structures. What it does prohibit—explicitly and…
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CRA vs. IRS Service Levels: A Cross-Border Comparison of Tax Administration Risks for Canadian and U.S. Taxpayers
Overview: Why Administrative Performance Matters in Cross-Border Tax Planning For taxpayers operating in both Canada and the United States, the effectiveness of tax administration can materially influence compliance costs, dispute…
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Accepting Money from a Spouse with Tax Problems can Give you a Bigger Problem with CRA: Panneton v. The King (2024 TCC 24)
Introduction: When Your Spouse’s Tax Debt Becomes Your Debt The decision in Panneton v. The King is an important reminder of how strictly Canadian courts apply section 160 of the…
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When CRA Employees Misbehave and Make Mistakes Against Canadian Taxpayers
What the CRA’s 2024–2025 Report Reveals About Accountability, Privacy, and Public Trust The Canada Revenue Agency occupies a central role in administering Canada’s tax system, collecting public revenue, and safeguarding…
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CRA Introduces Software-Specific Controls for EFILE Accounts, a Safety Feature, Starting in 2026
Beginning in February 2026, the Canada Revenue Agency will introduce a new control mechanism within the EFILE and ReFILE systems that directly affects how electronic tax returns are transmitted. Under…
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How to Properly Claim Employment Insurance Repayments and Protect Your Tax Relief: Lessons from Dandees v. The King (2025 TCC 171)
Overview — EI Repayments, Tax Brackets, and the Limits of Timing Relief In Dandees v. The King, 2025 TCC 171, the Tax Court of Canada addressed a common but often…
