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 [...]
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 [...]
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 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 [...]
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 [...]
Choosing the Right Lawyer for a Tax Dispute A tax dispute with the Canada Revenue Agency is not simply an accounting problem. It is a legal dispute with a sophisticated government authority that audits, reassesses, [...]
Why I Choose to Work from an Office and not Remotely People regularly ask me, 'why do you have this office? A lot of other tax lawyers work remotely.' Having an office is important to [...]
Citation: Minister of National Revenue v. Shopify Inc., 2025 FC 969Court: Federal Court of CanadaDate: May 29, 2025Judge: The Honourable Mr. Justice RégimbaldDocket: T-778-23 Overview This case involves the Minister of National Revenue’s attempt to [...]
