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 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 [...]
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 [...]
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 [...]
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 [...]
When Should a CPA Call a Tax Litigator? Most tax disputes are resolved long before a courtroom is ever involved. In many cases, a skilled CPA can manage compliance issues, respond to routine audit queries, [...]
The Role of a Tax Litigator During a Corporate Audit A corporate tax audit is not merely an accounting exercise. It is a structured adversarial process that can evolve—sometimes quickly—from information gathering to reassessment and, [...]
Are Uber Drivers Subject to HST? Boylu v. The King, 2025 TCC 192 (Informal Procedure) by Amit Ummat, Tax Litigator Facts The appellant was an Ontario-based Uber driver during 2015 and 2016. Riders booked [...]
Canadian Federal Budget Proposes Amendments to CRA’s Information Gathering Powers BUDGET FOUND HERE By: Amit Ummat Chrystia Freeland, the Canadian Deputy Prime Minister and the Minister of Finance, tabled the 2024 Canadian Federal Budget on [...]
CRA CAN COMPEL TAXPAYERS TO SUBMIT TO ORAL INTERVIEWS Pursuant to the newly enacted subparagraph 231.1(1)(d)(i) of the Income Tax Act, the CRA can now compel a taxpayer to submit to an oral interview. This [...]
