Rosen & Associates
Why You Need Rosen & Associates On Your Side
osen and Associates is a national tax law firm based in Toronto, Ontario. We take a proactive, client focused approach allowing our lawyers to provide comprehensive legal tax advice and representation.
Our focus and expertise is centered around the complex area of tax law, placing R&A Tax Law in a unique position to deliver the quality of service and legal tax defense rightfully expected by hardworking Canadians in their disputes against the Canada Revenue Agency.
If you are having trouble with the CRA or are experiencing taxation issues Rosen & Associates can help. We are especially skilled in the following practice areas:
Ontario Superior Court of Justice
Northcut v. Ontario (Minister of Finance), 184-17
The Minister raised a director’s liability assessment for unpaid taxes under the Retail Sales Tax Act. The taxpayer had effectively resigned more than two years prior to the aforementioned assessment being issued. By way of consent, the Minister vacated the assessment and revoked all legal action.
Tax Court of Canada
Juriansz v. HMQ, 2015-3945(IT)G
The Appellant was audited by the CRA for the disposition of two properties and the Minister erroneously concluded that both were sold on account of business. Furthermore, the Minister imposed gross negligence penalties for failing to report the above. R&A Tax Law successfully negotiated an early resolution wherein our client was entitled to the principle exemption on one of the properties and the other disposition was on account of capital. The gross negligence penalties were vacated and the GST/HST implications were removed entirely.
Sakaria v. HMQ, 2016-237(IT)G
The Canada Revenue Agency issued an assessment, pursuant to subsection 160(2) of the Income Tax Act, against the taxpayer for an unpaid tax liability of a relative. In exchange for title to a property, the taxpayer forgave previous loans that were advanced. The Tax Court of Canada agreed that debt forgiveness was valid consideration and as such the appeal was allowed, significantly reducing the assessed tax liability.
Chan v. HMQ, 2016-5049(IT)G
The taxpayer came to us in 2016 after the Canada Revenue Agency reassessed him based on the purchase and sale of a home. The CRA disallowed his Principal Residence claim, and reassessed him charging him for business income and gross negligence penalties because he had only lived in the home for a few months. The amount owing was $75,000. R&A Tax Law filed a Notice of Appeal in the Tax Court of Canada, and aggressively pursued the case knowing that he should be entitled to the Principal Residence Exemption. A few weeks before trial, we were successful in overturning the CRA decision. He has now been reassessed owing no taxes or penalties and is being allowed his Principal Residence Claim.
What People Say
After my free consultation with Jason, it was only a matter of days before my husband and I knew working with him was in our best interest. He made us feel comfortable and informed about the legal process. As a result, we were able to make an informed decision with his excellent guidance and experience.
After having my accountant abandon me during an audit I did not know what to do. I called R&A Tax Law and it could not have gone better. They helped me through the last part of my audit and got everything fixed after going through an objection. I went from owing $88,000 to the government done to $4,000!! Thanks again!
Thank you for all your efforts and hard work on behalf of my corporation. I couldn’t imagine going through it all without your team by my side.
We bring each client a combination of deep industry knowledge and expert perspectives from other industries on the challenge at stake, to offer our clients fresh perspectives and breakthrough business insights.
Tax Law Blog
Fresh perspectives and breakthrough news from the world of tax law.
When the Tax-Free Savings Account (TFSA) is Not Actually Free
The Cautionary Tale of Canadian Western Trust Company v The King. The TFSA is among one of Canadians favourite Registered Accounts for its Tax-Free...Read More
The CRA’s New Audit Powers
The expansion of the Canada Revenue Agency (CRA)’s audit powers in the 2021 federal budget came into force December 15, 2022. These changes mean that the...Read More
The CRA’s New Audit Powers
Goldhar v HMK, 2023 TCC 30
BACKGROUND Counsels of Record: Jason Rosen, Managing Partner; and Kendal Steele, Of Counsel. In this decision by the Tax Court of Canada,...Read More