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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 be...
Read More 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 back and...
Read More 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 tax...
Read More 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 “Requirement To Pay”...
Read More 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. Whether...
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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...
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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 financially...
Read More The Hidden Evidence that Wins Tax Court Appeals: Third-Party Records
Many taxpayers believe that once the Canada Revenue Agency “CRA” obtains third-party records, the outcome of an audit is inevitable. In reality, those...
Read More 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 to be self...
Read More The Burden of Proof in CRA Disputes: What Taxpayers Must Show
One of the most common misconceptions amongst taxpayers involved in disputes with the Canada Revenue Agency (“CRA”) concerns who bears the burden of proof....
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