When a CRA Audit Becomes a Tax Dispute
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
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?
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 [...]
When CRA Uses Your Own Accountant Against You
When CRA Uses Your Own Accountant Against You One of the biggest misconceptions about tax litigation is that cases are won or lost because one side finds a better legal precedent. In reality, many tax [...]
Estate Planning Is Really Tax Planning: Key Tax Tips and Traps Every Canadian Should Know
Estate Planning Is Really Tax Planning: Key Tax Tips and Traps Every Canadian Should Know Estate planning is often thought of as a discussion about wills, executors, and beneficiaries. While those are essential components, they [...]
The Risks of Pre-Construction Condo Flips
The Risks of Pre-Construction Condo Flips Qureshi v. The King 2026 TCC 87 DECISION HERE Summary In Qureshi v. The King 2026 TCC 87, the Tax Court of Canada (“Court”) dismissed both an income tax [...]
The Next Five Years: The Biggest Tax Issues Canadian Taxpayers Will Face
The Next Five Years: The Biggest Tax Issues Canadian Taxpayers Will Face By Amit Ummat, Certified Specialist in Taxation Law The Canada Revenue Agency is changing rapidly. Increased access to data, enhanced audit technology, expanded [...]
Estoppel in Canadian Law: The Different Types of Estoppel and Why They Matter
Estoppel in Canadian Law: The Different Types of Estoppel and Why They Matter The term “estoppel” is used constantly in litigation, yet many lawyers and clients use it as though it were a single doctrine. [...]
What Makes a Really Good Tax Accountant: A Tax Litigator’s Perspective
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
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 [...]