
Missing Deadlines in Tax Disputes: Why Procedure Still Matters
Background and Procedural History A recent decision from the Federal Court of Appeal serves as a strong reminder that, in tax disputes, procedure can ...
Reopening Statute-Barred Tax Years: Lessons from Marleau v. The King
Overview of the Decision The recent Tax Court of Canada decision in Marleau v. The King explains when the Canada Revenue Agency (“CRA”) can go bac...
Bare Trusts in Real Estate: When to Use Them and How They Affect Taxation
Bare trusts can be a useful tool in real estate transactions for privacy and tax neutrality, yet they are often misunderstood or overlooked. Like all ...
Understanding Requirements to Pay
Being on the receiving end of legal action from the Canada Revenue Agency (“CRA”) can be incredibly stressful. Taxpayers who receive a “Requirem...
Navigating Properties with CRA Liens: What Sellers Need to Know
Selling a property already comes with many stresses and complexities, but when the CRA places a lien on the property, those complexities increase. Whe...
When Is the Sale of Your Home Taxed as Business Income in Canada?
Buying a home is often one of the largest investments a Canadian taxpayer will make. What many homeowners do not realize, however, is that selling a p...
How Tax Lawyers Help Navigate Complex Tax Controversies
When the Canada Revenue Agency (“CRA”) challenges a taxpayer filings or issues a reassessment, the resulting dispute can be both stressful and fin...
Tax Controversy in GST/HST Audits and Disputes
The Goods and Services Tax (“GST”) and Harmonized Sales Tax (“HST”) systems play a central role in Canada indirect tax regime. While designed ...
Common Causes of Tax Controversy with the CRA
Tax controversy arises when a taxpayer and the Canada Revenue Agency (“CRA”) disagree over how the Income Tax Act or Excise Tax Act applies to a p...