CRA Articles

by Elias Zafiridis

Owner-Manager Remuneration: Characterization of Payments

The Background The recent case involving Malamute Contracting Inc., a small Ontario business specializing in kitchen and bathroom renovations, highlig...

by Elias Zafiridis

CRA Interest Relief: Reduce or Eliminate Interest

Tax debt can quickly become overwhelming, especially when daily compound interest adds up over time. Fortunately, the Canada Revenue Agency (“CR...

by Stephanie Emmanuel

The Consequences of Missing CRA Appeal Deadlines: Amarpal Singh Personal Real Estate Corporation v The King

In Amarpal Singh Personal Real Estate Corporation v The King, 2025 TCC 38, Justice Spiro emphasized the critical importance of meeting deadlines under...

by Laura Hinton

Ontario’s 25% Electricity Surcharge: Navigating Trade Tensions with the U.S

In response to escalating trade tensions, Ontario’s Premier, Doug Ford, recently announced a 25% surcharge on electricity exports to a number of sta...

by Neil La Marca

The Tax Implications of Moving During COVID-19: What the Recent Khani Case Means for Remote Workers

The COVID-19 pandemic reshaped the way we work, pushing millions of Canadians into remote roles temporarily and for some permanently. For many, the tr...

by Jeffrey Liu

Boles v The King: Is Your Side Hustle A Taxable Business?

In a recently published decision concerning the case of Boles v the King, 2024 TCC 167, the Tax Court of Canada (the “TCC”) provides further guida...

by Jeffrey Liu

Rudolph v The King: Are the Proceeds of Your Share Disposition Business Income or Capital Gains?

In Rudolph v the King, 2024 TCC 148, Justice Lafleur provides an overview of the law regarding the factors that must be considered in determining whet...

by Neil La Marca

Sim v The King: Examining Non-Parties in Tax Court Proceedings

Individuals involved with closely held private corporations, whether as directors, former directors, or employees, may find themselves called upon to ...

by Stephen Mather

Canadian Government Defers Capital Gains Inclusion Rate to January 1, 2026

The newly appointed Minister of Finance, successor to Minister Freeland, Dominic LeBlanc recently announced an amendment to the legislative changes th...

by Stephen Mather

Judicial Review of the CRA Preemptive Action on Capital Gains Rate Changes

On January 8, 2025, the Canada Revenue Agency (CRA) announced that, for the upcoming tax season, it will proceed with administering the proposed capit...