Purpose, Process and the Reach of CRA Requirements Minister of National Revenue v. Zeifmans LLP 2026 FCA 147 Summary In Minister of National Revenue v. Zeifmans LLP[1], the Federal Court of Appeal (“FCA”) ordered the [...]
The Careful Taxpayer: Due Diligence at the Intersection of Penalties, Disclosure and GAAR Amit Ummat | Principal Counsel, Ummat Tax Law PC Introduction Canadian tax law separates the correctness of a tax position from the [...]
The Tax Debt That Never Dies: Why Parliament Must Reform Section 160 Canada needs a principled limit on transferee liability without giving tax debtors a road map for avoiding collection By Amit Ummat, Principal Counsel, [...]
Canada’s Productivity Mega Deduction: A Fundamental Shift in the Tax Treatment of Business Investment On September 15, 2026, the federal government released draft legislation for what it calls the Productivity Mega Deduction. The name may [...]
When the CRA Demands an Interview: The Expanding Power to Compel Answers During a Tax Audit A Canada Revenue Agency audit is no longer confined to the production of books, records and supporting documents. The [...]
Going to the Tax Court Without a Lawyer: What Every Self-Represented Litigant Should Know By Amit Ummat, Principal Counsel, Ummat Tax Law PC The Tax Court of Canada is intended to be accessible. A taxpayer [...]
Access to Justice or Second-Class Justice? The Proposed Expansion of the Tax Court’s Informal Procedure Introduction Bill C-31, the Budget 2025 Implementation Act, No. 2, proposes a substantial expansion of the Tax Court of Canada’s [...]
When a CRA Audit Becomes a Tax Dispute The decisions made before a proposal letter often determine whether the client can still win later The central point: an audit response does more than answer an [...]
CRA Collections During Tax Disputes: Why GST/HST Assessments Require the Same Basic Protection as Income Tax Assessments Introduction A tax assessment is not a judgment. It is the Canada Revenue Agency’s administrative determination of a [...]
Can You Deduct the Cost of Fighting the CRA? A tax dispute can be expensive. Accountants must reconstruct records, lawyers prepare objections and appeals, experts provide reports, and years may pass before the matter is [...]
