What Makes a Really Good Tax Accountant: A Tax Litigator’s Perspective Most people think a good tax accountant is someone who files returns on time, finds deductions, and keeps clients out of trouble with the [...]
Common Income Tax and GST/HST Elections and Timing Traps in Canada One of the most overlooked areas in Canadian tax practice is the role of elections. Clients often assume that tax results flow automatically from [...]
Interest Relief Applications Demystified An application for interest relief in Canada is, at its core, a request to the Canada Revenue Agency to exercise discretion to cancel or waive interest that has accrued on a [...]
Rethinking Tax Simplicity in Canada: A Serious Case for Reform Canada’s tax system has reached a point where complexity is no longer a byproduct of sophistication but a structural problem in itself. Complexity now functions [...]
Tax Pitfalls in Buying and Selling a Business Buying or selling a business is often treated as a commercial transaction first and a tax transaction second. That is a mistake. In practice, many of the [...]
When Financial Statements Quietly Create Tax Litigation Problems One of the more overlooked causes of difficult tax litigation is not aggressive tax planning, offshore structures, or complicated corporate reorganizations. It is the ordinary set of [...]
The Stoic Tax Professional: Part 2 This is an update to an article I wrote in 2020 about how stoic principles and exercises apply to a person working specifically in tax. You can find it [...]
Economic Entity Audits in Canada: Scope, Risk, and Strategic Pushback An “economic entity audit” is not a defined term in the Income Tax Act or Excise Tax Act, but it is a label commonly used [...]
Rectification in the Canadian Tax Context Rectification is an equitable remedy that permits a court to amend a written instrument where it fails to accurately record the agreement that the parties in fact reached. In [...]
The Intersection Between Real Estate Law and Tax Litigation in Canada: Income Tax and GST Considerations Introduction Few areas of Canadian tax litigation generate as much complexity as disputes involving real estate. Real estate transactions [...]
