Author: Sung Samson An

by Sung Samson An

The Limits on Limits: A Brief Overview of Taxpayers’ Procedural Rights

An essential part of our taxation regime is the right to appeal the Canada Revenue Agency’s (the “CRA’s”) assessments and reassessments throug...

by Sung Samson An

Tragedy of the Commons – Bankruptcy, Insolvency, and Tax Debt

As the world enters 2023, there are certainly worries of impending recessions. In the face of economic crisis, bankruptcies and insolvencies are to be...

by Sung Samson An

Streaming and Taxation

With the introduction of YouTube Shorts, the Google-Alphabet-YouTube conglomerate is fighting for the niche market largely dominated by TikTok. But Tw...

by Sung Samson An

Canadian Foreign Affiliates, FAPI, and Upcoming Legislative Changes

On August 9, 2022, Canada’s Ministry of Finance released details of proposed changes to the Income Tax Act (“ITA”), many of which are dr...