ONTARIO COVID-19 BUSINESS SUPPORT GRANTS: ONTARIO TAX The Ontario Small Business Support Grant – Funding Availability and Limits. The Ontario Small Business Support Grant is a is a one-time grant that is available to eligible small businesses across Ontario. In particular, small businesses may be eligible to receive the minimum of $10,000 and up to a maximum of $20,000. REFUNDABLE DIVIDEND TAX ON HAND Refundable dividend tax on hand accumulates in a corporation that earns passive (investment) income until a taxable dividend is paid out to shareholders (thereby being taxed in the shareholder’s hands). The corporation will then recover a percentage of the dividends paid from its RDTOH account. This article will examine some of the key

pieces

BARE TRUSTS TAX CONSEQUENCES: CANADIAN TAX LAWYER GUIDANCE Introduction: Bare Trusts & Canadian Tax Law. This article aims to provide tax advice to Canadian taxpayers on the concept of a bare trust. In particular, it discusses three key topics concerning a bare-trust relationship—namely, its nature, its relevance for Canadian tax purposes, and the indicia proving its existence. TAXATION OF SETTLEMENT AMOUNTS CANADIAN DEPARTURE, RRSPS AND TSFAS FOR NON-RESIDENTS: TAX When non-residents receive certain income from Canada, that income is subject to withholding tax. As the name suggests, withholding tax requires the payor to withhold a certain percentage of the income and remit this to Canada Revenue Agency (CRA) as tax on the income. The withholding tax rate is 25% unless varied by a tax treaty. DIVIDEND TYPES UNDER THE CANADIAN INCOME TAX ACT Eligible Dividends vs. Non-Eligible Dividends. An important concept in Canadian tax law is the idea of tax integration. In a general sense, integration is the idea that the ultimate income tax rate of a particular stream of income once it reaches the hands of the individual should be approximately the same tax rate regardless of how he decides to organize his affairs. PURCHASE & SALE HYBRID TRANSACTION STRUCTURESEE MORE ON TAXPAGE.COM ONTARIO COVID-19 BUSINESS SUPPORT GRANTS: ONTARIO TAX The Ontario Small Business Support Grant – Funding Availability and Limits. The Ontario Small Business Support Grant is a is a one-time grant that is available to eligible small businesses across Ontario. In particular, small businesses may be eligible to receive the minimum of $10,000 and up to a maximum of $20,000. REFUNDABLE DIVIDEND TAX ON HAND Refundable dividend tax on hand accumulates in a corporation that earns passive (investment) income until a taxable dividend is paid out to shareholders (thereby being taxed in the shareholder’s hands). The corporation will then recover a percentage of the dividends paid from its RDTOH account. This article will examine some of the key

pieces

BARE TRUSTS TAX CONSEQUENCES: CANADIAN TAX LAWYER GUIDANCE Introduction: Bare Trusts & Canadian Tax Law. This article aims to provide tax advice to Canadian taxpayers on the concept of a bare trust. In particular, it discusses three key topics concerning a bare-trust relationship—namely, its nature, its relevance for Canadian tax purposes, and the indicia proving its existence. TAXATION OF SETTLEMENT AMOUNTS CANADIAN DEPARTURE, RRSPS AND TSFAS FOR NON-RESIDENTS: TAX When non-residents receive certain income from Canada, that income is subject to withholding tax. As the name suggests, withholding tax requires the payor to withhold a certain percentage of the income and remit this to Canada Revenue Agency (CRA) as tax on the income. The withholding tax rate is 25% unless varied by a tax treaty. DIVIDEND TYPES UNDER THE CANADIAN INCOME TAX ACT Eligible Dividends vs. Non-Eligible Dividends. An important concept in Canadian tax law is the idea of tax integration. In a general sense, integration is the idea that the ultimate income tax rate of a particular stream of income once it reaches the hands of the individual should be approximately the same tax rate regardless of how he decides to organize his affairs. PURCHASE & SALE HYBRID TRANSACTION STRUCTURESEE MORE ON TAXPAGE.COM

TORONTO TAX LAWYER

CRA Tax Audits. There are over 350,000 tax audit and review actions conducted by the Canada Revenue Agency on a yearly basis. Around 15,000 of these tax audits deal with “cash only” businesses (i.e. the underground economy). Additionally, an estimated 35,000 are tax

shelter audits.

CANADIAN CONTROLLED PRIVATE CORPORATION: CANADIAN TAX A CCPC has many corporate tax benefits and the biggest one is small business deduction that reduces Part I tax the corporation would otherwise have to pay. Although the general corporate tax rate is 28% after federal abatement, a CCPC only pays a reduced tax rate of 9%. However, the reduced rate only applies to the first $500, 000 of

active

QUALIFYING FOR SMALL BUSINESS DEDUCTION: CANADIAN TAX There are multiple requirements in order to be eligible for the small business deduction. First, the business must be a Canadian-Controlled Private Corporation (“CCPC”). Under subsection 125 (7) of the Income Tax Act, a business will qualify as a CCPC if it meets three criteria: It is a private corporation, meaning its shares are not

traded

DIVIDEND TYPES UNDER THE CANADIAN INCOME TAX ACT Eligible Dividends vs. Non-Eligible Dividends. An important concept in Canadian tax law is the idea of tax integration. In a general sense, integration is the idea that the ultimate income tax rate of a particular stream of income once it reaches the hands of the individual should be approximately the same tax rate regardless of how he decides to organize his affairs. CANADIAN TAXATION OF CROWDFUNDING Canadian Taxation of Crowdfunding—A Canadian Tax Lawyer Analysis What is Crowdfunding? As the name suggests, crowdfunding is a manner of raising funds from a large number of people. Recently, websites such as Kickstarter, Kiva, IndieGoGo, and Microventures have drawn attention to the practice. But crowdfunding has a long history. During the Second World War, Canada SECTION 85 ROLLOVERS: A CANADIAN TAX LAWYER’S GUIDE Introduction – Tax-Deferred Transfers of Property to a Corporation. Section 85 of the Federal Income Tax Act (“Tax Act”), also known as a rollover provision, outlines the conditions required for a tax-deferred transfer of eligible property by a taxpayer (“transferor”) to a taxable Canadian corporation (“transferee”).Rollover provisions are a valuable tax planning

tool because

TAX TREATMENT OF US-OWNED CANADIAN ULC Article IV(7)(b) also denies treaty benefits to a US corporation that receives income from a Canadian ULC. Dividends and royalties paid by a ULC directly to a US corporation are denied treaty benefits, if the ULC is an FTE: the income’s US tax treatment differs from what would have been its tax treatment, if the ULC had not been an FTE. CHANGES TO THE ELIGIBLE CAPITAL PROPERTY TAX RULES A $500,000 capital dividend may be declared, allowing the operating corporation to pay out an amount of $500,000 on a tax-free basis to the shareholder (s); and. Passive income of $500,000 earned by the operating corporation. This amount will be subject to Part IV tax at a rate of 50.67% – a total tax payable by the corporation of $253,350. TRANSFERRING FOREIGN PENSION TO RRSP: A CANADIAN TAX Paragraph 60 (j) effectively allows a Canadian tax resident to cash out a foreign pension and transfer the proceeds to an RRSP on a tax-deferred basis. The taxpayer still reports the foreign pension as income, but, if the taxpayer satisfies the conditions of subparagraphs 60 (j) (i), 60 (j) (iii), and 60 (j) (iv), the taxpayer may fully

deduct

IS BITCOIN TAXABLE IN CANADA? CRA TAX TREATMENT OF BITCOINS Bitcoins are a type of virtual currency known as “cryptocurrency” and originally created by an anonymous computer programmer in 2009. Because Bitcoins are designed to allow for anonymous exchanges, they have become a cause for concern for income tax and other authorities the world over due to the potential for money laundering and other

illegal activities.

TAXATION OF SETTLEMENT AMOUNTS CANADIAN CONTROLLED PRIVATE CORPORATION: CANADIAN TAX A CCPC has many corporate tax benefits and the biggest one is small business deduction that reduces Part I tax the corporation would otherwise have to pay. Although the general corporate tax rate is 28% after federal abatement, a CCPC only pays a reduced tax rate of 9%. However, the reduced rate only applies to the first $500, 000 of

active

ONTARIO COVID-19 BUSINESS SUPPORT GRANTS: ONTARIO TAX Introduction – Ontario’s COVID-19 Business Support Grants. Many Ontario small businesses have been financially impacted by the ongoing COVID-19 pandemic specifically by Ontario’s province wide shut down that has been in effect since 12:01 am on December 26, 2021. While some businesses are able to operate, but not at full capacity, others are forced to temporarily shut down due to public BARE TRUSTS TAX CONSEQUENCES: CANADIAN TAX LAWYER GUIDANCE Introduction: Bare Trusts & Canadian Tax Law. This article aims to provide tax advice to Canadian taxpayers on the concept of a bare trust. In particular, it discusses three key topics concerning a bare-trust relationship—namely, its nature, its relevance for Canadian tax purposes, and the indicia proving its existence. QUALIFYING FOR SMALL BUSINESS DEDUCTION: CANADIAN TAX There are multiple requirements in order to be eligible for the small business deduction. First, the business must be a Canadian-Controlled Private Corporation (“CCPC”). Under subsection 125 (7) of the Income Tax Act, a business will qualify as a CCPC if it meets three criteria: It is a private corporation, meaning its shares are not

traded

PURCHASE & SALE HYBRID TRANSACTION STRUCTURESEE MORE ON TAXPAGE.COM TAXATION OF TESTAMENTARY TRUSTS The taxation of testamentary trusts is a complex area of law that requires detailed analysis and advice from an experienced Canadian tax lawyer. If you are a trustee of a testamentary trust you should consider further steps that could be taken to minimize the trust’s tax liability. If you have a trust included in your last will and

testament

TAX TREATMENT OF US-OWNED CANADIAN ULC Article IV(7)(b) also denies treaty benefits to a US corporation that receives income from a Canadian ULC. Dividends and royalties paid by a ULC directly to a US corporation are denied treaty benefits, if the ULC is an FTE: the income’s US tax treatment differs from what would have been its tax treatment, if the ULC had not been an FTE. EMPLOYEE STOCK OPTIONS: TAX IMPLICATIONS FOR CANADIAN Employee benefit: The employee’s benefit from exercising the employee stock option is $15 – $10 = $5 – ½ under subsection 110 (1) = $2.50. The employee includes the benefit either in the year she exercised the employee stock option or, if she acquired CCPC shares, in the year that she sells the shares. IS BITCOIN TAXABLE IN CANADA? CRA TAX TREATMENT OF BITCOINS Bitcoins are a type of virtual currency known as “cryptocurrency” and originally created by an anonymous computer programmer in 2009. Because Bitcoins are designed to allow for anonymous exchanges, they have become a cause for concern for income tax and other authorities the world over due to the potential for money laundering and other

illegal activities.

TAXATION OF SETTLEMENT AMOUNTS CANADIAN CONTROLLED PRIVATE CORPORATION: CANADIAN TAX A CCPC has many corporate tax benefits and the biggest one is small business deduction that reduces Part I tax the corporation would otherwise have to pay. Although the general corporate tax rate is 28% after federal abatement, a CCPC only pays a reduced tax rate of 9%. However, the reduced rate only applies to the first $500, 000 of

active

ONTARIO COVID-19 BUSINESS SUPPORT GRANTS: ONTARIO TAX Introduction – Ontario’s COVID-19 Business Support Grants. Many Ontario small businesses have been financially impacted by the ongoing COVID-19 pandemic specifically by Ontario’s province wide shut down that has been in effect since 12:01 am on December 26, 2021. While some businesses are able to operate, but not at full capacity, others are forced to temporarily shut down due to public BARE TRUSTS TAX CONSEQUENCES: CANADIAN TAX LAWYER GUIDANCE Introduction: Bare Trusts & Canadian Tax Law. This article aims to provide tax advice to Canadian taxpayers on the concept of a bare trust. In particular, it discusses three key topics concerning a bare-trust relationship—namely, its nature, its relevance for Canadian tax purposes, and the indicia proving its existence. QUALIFYING FOR SMALL BUSINESS DEDUCTION: CANADIAN TAX There are multiple requirements in order to be eligible for the small business deduction. First, the business must be a Canadian-Controlled Private Corporation (“CCPC”). Under subsection 125 (7) of the Income Tax Act, a business will qualify as a CCPC if it meets three criteria: It is a private corporation, meaning its shares are not

traded

PURCHASE & SALE HYBRID TRANSACTION STRUCTURESEE MORE ON TAXPAGE.COM TAXATION OF TESTAMENTARY TRUSTS The taxation of testamentary trusts is a complex area of law that requires detailed analysis and advice from an experienced Canadian tax lawyer. If you are a trustee of a testamentary trust you should consider further steps that could be taken to minimize the trust’s tax liability. If you have a trust included in your last will and

testament

TAX TREATMENT OF US-OWNED CANADIAN ULC Article IV(7)(b) also denies treaty benefits to a US corporation that receives income from a Canadian ULC. Dividends and royalties paid by a ULC directly to a US corporation are denied treaty benefits, if the ULC is an FTE: the income’s US tax treatment differs from what would have been its tax treatment, if the ULC had not been an FTE. EMPLOYEE STOCK OPTIONS: TAX IMPLICATIONS FOR CANADIAN Employee benefit: The employee’s benefit from exercising the employee stock option is $15 – $10 = $5 – ½ under subsection 110 (1) = $2.50. The employee includes the benefit either in the year she exercised the employee stock option or, if she acquired CCPC shares, in the year that she sells the shares. IS BITCOIN TAXABLE IN CANADA? CRA TAX TREATMENT OF BITCOINS Bitcoins are a type of virtual currency known as “cryptocurrency” and originally created by an anonymous computer programmer in 2009. Because Bitcoins are designed to allow for anonymous exchanges, they have become a cause for concern for income tax and other authorities the world over due to the potential for money laundering and other

illegal activities.

TORONTO TAX LAWYER

CRA Tax Audits. There are over 350,000 tax audit and review actions conducted by the Canada Revenue Agency on a yearly basis. Around 15,000 of these tax audits deal with “cash only” businesses (i.e. the underground economy). Additionally, an estimated 35,000 are tax

shelter audits.

QUALIFYING FOR SMALL BUSINESS DEDUCTION: CANADIAN TAX There are multiple requirements in order to be eligible for the small business deduction. First, the business must be a Canadian-Controlled Private Corporation (“CCPC”). Under subsection 125 (7) of the Income Tax Act, a business will qualify as a CCPC if it meets three criteria: It is a private corporation, meaning its shares are not

traded

REFUNDABLE DIVIDEND TAX ON HAND Refundable dividend tax on hand accumulates in a corporation that earns passive (investment) income until a taxable dividend is paid out to shareholders (thereby being taxed in the shareholder’s hands). The corporation will then recover a percentage of the dividends paid from its RDTOH account. This article will examine some of the key

pieces

CANADIAN DEPARTURE, RRSPS AND TSFAS FOR NON-RESIDENTS: TAX RRSPs are not subject to departure tax. A taxpayer can file a section 217 election with respect to income from his or her RRSP. If a taxpayer used his or her RRSP to participate in the Home Buyer’s Plan, repayment of the amount withdrawn will follow particular rules based on whether the non-resident has built or bought a qualifying home when he or she become a non-resident. TRANSFERRING FOREIGN PENSION TO RRSP: A CANADIAN TAX Paragraph 60 (j) effectively allows a Canadian tax resident to cash out a foreign pension and transfer the proceeds to an RRSP on a tax-deferred basis. The taxpayer still reports the foreign pension as income, but, if the taxpayer satisfies the conditions of subparagraphs 60 (j) (i), 60 (j) (iii), and 60 (j) (iv), the taxpayer may fully

deduct

CHANGES TO THE ELIGIBLE CAPITAL PROPERTY TAX RULES A $500,000 capital dividend may be declared, allowing the operating corporation to pay out an amount of $500,000 on a tax-free basis to the shareholder (s); and. Passive income of $500,000 earned by the operating corporation. This amount will be subject to Part IV tax at a rate of 50.67% – a total tax payable by the corporation of $253,350. EMPLOYEE STOCK OPTIONS: TAX IMPLICATIONS FOR CANADIAN Employee benefit: The employee’s benefit from exercising the employee stock option is $15 – $10 = $5 – ½ under subsection 110 (1) = $2.50. The employee includes the benefit either in the year she exercised the employee stock option or, if she acquired CCPC shares, in the year that she sells the shares. LIMITED PARTNERSHIP LOSSES AND THE AT-RISK AMOUNT Limited Partnership Losses – Limited Partnership Losses and the At-risk Amount. The Canadian Income Tax legislation covering limited partnerships is designed to prevent limited partners from claiming losses in excess of the money that they have put “at-risk” by virtue of their investment in the limited partnership. CAPITAL-GAINS IMPLICATIONS OF GIFTS & OTHER NON-ARM’S Introduction – Taxation of Capital Gains in Canada Generally, when a taxpayer disposes of a capital property—e.g., real property, corporate shares, a partnership interest, mutual funds, etc.—and realizes a capital gain, the taxpayer must include one-half of the gain in his or her income. In other words, only half of a capital gain

is taxable.

IS BITCOIN TAXABLE IN CANADA? CRA TAX TREATMENT OF BITCOINS Bitcoins are a type of virtual currency known as “cryptocurrency” and originally created by an anonymous computer programmer in 2009. Because Bitcoins are designed to allow for anonymous exchanges, they have become a cause for concern for income tax and other authorities the world over due to the potential for money laundering and other

illegal activities.

TAXATION OF SETTLEMENT AMOUNTS CANADIAN CONTROLLED PRIVATE CORPORATION: CANADIAN TAX A CCPC has many corporate tax benefits and the biggest one is small business deduction that reduces Part I tax the corporation would otherwise have to pay. Although the general corporate tax rate is 28% after federal abatement, a CCPC only pays a reduced tax rate of 9%. However, the reduced rate only applies to the first $500, 000 of

active

ONTARIO COVID-19 BUSINESS SUPPORT GRANTS: ONTARIO TAX Introduction – Ontario’s COVID-19 Business Support Grants. Many Ontario small businesses have been financially impacted by the ongoing COVID-19 pandemic specifically by Ontario’s province wide shut down that has been in effect since 12:01 am on December 26, 2021. While some businesses are able to operate, but not at full capacity, others are forced to temporarily shut down due to public BARE TRUSTS TAX CONSEQUENCES: CANADIAN TAX LAWYER GUIDANCE Introduction: Bare Trusts & Canadian Tax Law. This article aims to provide tax advice to Canadian taxpayers on the concept of a bare trust. In particular, it discusses three key topics concerning a bare-trust relationship—namely, its nature, its relevance for Canadian tax purposes, and the indicia proving its existence. QUALIFYING FOR SMALL BUSINESS DEDUCTION: CANADIAN TAX There are multiple requirements in order to be eligible for the small business deduction. First, the business must be a Canadian-Controlled Private Corporation (“CCPC”). Under subsection 125 (7) of the Income Tax Act, a business will qualify as a CCPC if it meets three criteria: It is a private corporation, meaning its shares are not

traded

PURCHASE & SALE HYBRID TRANSACTION STRUCTURESEE MORE ON TAXPAGE.COM TAXATION OF TESTAMENTARY TRUSTS The taxation of testamentary trusts is a complex area of law that requires detailed analysis and advice from an experienced Canadian tax lawyer. If you are a trustee of a testamentary trust you should consider further steps that could be taken to minimize the trust’s tax liability. If you have a trust included in your last will and

testament

TAX TREATMENT OF US-OWNED CANADIAN ULC Article IV(7)(b) also denies treaty benefits to a US corporation that receives income from a Canadian ULC. Dividends and royalties paid by a ULC directly to a US corporation are denied treaty benefits, if the ULC is an FTE: the income’s US tax treatment differs from what would have been its tax treatment, if the ULC had not been an FTE. EMPLOYEE STOCK OPTIONS: TAX IMPLICATIONS FOR CANADIAN Employee benefit: The employee’s benefit from exercising the employee stock option is $15 – $10 = $5 – ½ under subsection 110 (1) = $2.50. The employee includes the benefit either in the year she exercised the employee stock option or, if she acquired CCPC shares, in the year that she sells the shares. IS BITCOIN TAXABLE IN CANADA? CRA TAX TREATMENT OF BITCOINS Bitcoins are a type of virtual currency known as “cryptocurrency” and originally created by an anonymous computer programmer in 2009. Because Bitcoins are designed to allow for anonymous exchanges, they have become a cause for concern for income tax and other authorities the world over due to the potential for money laundering and other

illegal activities.

TAXATION OF SETTLEMENT AMOUNTS CANADIAN CONTROLLED PRIVATE CORPORATION: CANADIAN TAX A CCPC has many corporate tax benefits and the biggest one is small business deduction that reduces Part I tax the corporation would otherwise have to pay. Although the general corporate tax rate is 28% after federal abatement, a CCPC only pays a reduced tax rate of 9%. However, the reduced rate only applies to the first $500, 000 of

active

ONTARIO COVID-19 BUSINESS SUPPORT GRANTS: ONTARIO TAX Introduction – Ontario’s COVID-19 Business Support Grants. Many Ontario small businesses have been financially impacted by the ongoing COVID-19 pandemic specifically by Ontario’s province wide shut down that has been in effect since 12:01 am on December 26, 2021. While some businesses are able to operate, but not at full capacity, others are forced to temporarily shut down due to public BARE TRUSTS TAX CONSEQUENCES: CANADIAN TAX LAWYER GUIDANCE Introduction: Bare Trusts & Canadian Tax Law. This article aims to provide tax advice to Canadian taxpayers on the concept of a bare trust. In particular, it discusses three key topics concerning a bare-trust relationship—namely, its nature, its relevance for Canadian tax purposes, and the indicia proving its existence. QUALIFYING FOR SMALL BUSINESS DEDUCTION: CANADIAN TAX There are multiple requirements in order to be eligible for the small business deduction. First, the business must be a Canadian-Controlled Private Corporation (“CCPC”). Under subsection 125 (7) of the Income Tax Act, a business will qualify as a CCPC if it meets three criteria: It is a private corporation, meaning its shares are not

traded

PURCHASE & SALE HYBRID TRANSACTION STRUCTURESEE MORE ON TAXPAGE.COM TAXATION OF TESTAMENTARY TRUSTS The taxation of testamentary trusts is a complex area of law that requires detailed analysis and advice from an experienced Canadian tax lawyer. If you are a trustee of a testamentary trust you should consider further steps that could be taken to minimize the trust’s tax liability. If you have a trust included in your last will and

testament

TAX TREATMENT OF US-OWNED CANADIAN ULC Article IV(7)(b) also denies treaty benefits to a US corporation that receives income from a Canadian ULC. Dividends and royalties paid by a ULC directly to a US corporation are denied treaty benefits, if the ULC is an FTE: the income’s US tax treatment differs from what would have been its tax treatment, if the ULC had not been an FTE. EMPLOYEE STOCK OPTIONS: TAX IMPLICATIONS FOR CANADIAN Employee benefit: The employee’s benefit from exercising the employee stock option is $15 – $10 = $5 – ½ under subsection 110 (1) = $2.50. The employee includes the benefit either in the year she exercised the employee stock option or, if she acquired CCPC shares, in the year that she sells the shares. IS BITCOIN TAXABLE IN CANADA? CRA TAX TREATMENT OF BITCOINS Bitcoins are a type of virtual currency known as “cryptocurrency” and originally created by an anonymous computer programmer in 2009. Because Bitcoins are designed to allow for anonymous exchanges, they have become a cause for concern for income tax and other authorities the world over due to the potential for money laundering and other

illegal activities.

TORONTO TAX LAWYER

CRA Tax Audits. There are over 350,000 tax audit and review actions conducted by the Canada Revenue Agency on a yearly basis. Around 15,000 of these tax audits deal with “cash only” businesses (i.e. the underground economy). Additionally, an estimated 35,000 are tax

shelter audits.

QUALIFYING FOR SMALL BUSINESS DEDUCTION: CANADIAN TAX There are multiple requirements in order to be eligible for the small business deduction. First, the business must be a Canadian-Controlled Private Corporation (“CCPC”). Under subsection 125 (7) of the Income Tax Act, a business will qualify as a CCPC if it meets three criteria: It is a private corporation, meaning its shares are not

traded

REFUNDABLE DIVIDEND TAX ON HAND Refundable dividend tax on hand accumulates in a corporation that earns passive (investment) income until a taxable dividend is paid out to shareholders (thereby being taxed in the shareholder’s hands). The corporation will then recover a percentage of the dividends paid from its RDTOH account. This article will examine some of the key

pieces

CANADIAN DEPARTURE, RRSPS AND TSFAS FOR NON-RESIDENTS: TAX RRSPs are not subject to departure tax. A taxpayer can file a section 217 election with respect to income from his or her RRSP. If a taxpayer used his or her RRSP to participate in the Home Buyer’s Plan, repayment of the amount withdrawn will follow particular rules based on whether the non-resident has built or bought a qualifying home when he or she become a non-resident. TRANSFERRING FOREIGN PENSION TO RRSP: A CANADIAN TAX Paragraph 60 (j) effectively allows a Canadian tax resident to cash out a foreign pension and transfer the proceeds to an RRSP on a tax-deferred basis. The taxpayer still reports the foreign pension as income, but, if the taxpayer satisfies the conditions of subparagraphs 60 (j) (i), 60 (j) (iii), and 60 (j) (iv), the taxpayer may fully

deduct

CHANGES TO THE ELIGIBLE CAPITAL PROPERTY TAX RULES A $500,000 capital dividend may be declared, allowing the operating corporation to pay out an amount of $500,000 on a tax-free basis to the shareholder (s); and. Passive income of $500,000 earned by the operating corporation. This amount will be subject to Part IV tax at a rate of 50.67% – a total tax payable by the corporation of $253,350. EMPLOYEE STOCK OPTIONS: TAX IMPLICATIONS FOR CANADIAN Employee benefit: The employee’s benefit from exercising the employee stock option is $15 – $10 = $5 – ½ under subsection 110 (1) = $2.50. The employee includes the benefit either in the year she exercised the employee stock option or, if she acquired CCPC shares, in the year that she sells the shares. LIMITED PARTNERSHIP LOSSES AND THE AT-RISK AMOUNT Limited Partnership Losses – Limited Partnership Losses and the At-risk Amount. The Canadian Income Tax legislation covering limited partnerships is designed to prevent limited partners from claiming losses in excess of the money that they have put “at-risk” by virtue of their investment in the limited partnership. CAPITAL-GAINS IMPLICATIONS OF GIFTS & OTHER NON-ARM’S Introduction – Taxation of Capital Gains in Canada Generally, when a taxpayer disposes of a capital property—e.g., real property, corporate shares, a partnership interest, mutual funds, etc.—and realizes a capital gain, the taxpayer must include one-half of the gain in his or her income. In other words, only half of a capital gain

is taxable.

IS BITCOIN TAXABLE IN CANADA? CRA TAX TREATMENT OF BITCOINS Bitcoins are a type of virtual currency known as “cryptocurrency” and originally created by an anonymous computer programmer in 2009. Because Bitcoins are designed to allow for anonymous exchanges, they have become a cause for concern for income tax and other authorities the world over due to the potential for money laundering and other

illegal activities.

CANADIAN CONTROLLED PRIVATE CORPORATION: CANADIAN TAX A CCPC has many corporate tax benefits and the biggest one is small business deduction that reduces Part I tax the corporation would otherwise have to pay. Although the general corporate tax rate is 28% after federal abatement, a CCPC only pays a reduced tax rate of 9%. However, the reduced rate only applies to the first $500, 000 of

active

TAXATION OF TESTAMENTARY TRUSTS The taxation of testamentary trusts is a complex area of law that requires detailed analysis and advice from an experienced Canadian tax lawyer. If you are a trustee of a testamentary trust you should consider further steps that could be taken to minimize the trust’s tax liability. If you have a trust included in your last will and

testament

BARE TRUSTS TAX CONSEQUENCES: CANADIAN TAX LAWYER GUIDANCE Introduction: Bare Trusts & Canadian Tax Law. This article aims to provide tax advice to Canadian taxpayers on the concept of a bare trust. In particular, it discusses three key topics concerning a bare-trust relationship—namely, its nature, its relevance for

Canadian tax

TAX FREE CAPITAL DIVIDENDS Tax Free Capital Dividends – Elections and Penalties – A Toronto Tax Lawyer Analysis Capital dividends are a useful method for Canadian private corporations to distribute tax free funds to their shareholders. Corporations can declare these capital dividends which their shareholders can receive tax-free. However, a corporation should be cognizant of the amount in their TAXATION OF SETTLEMENT AMOUNTS PURCHASE & SALE HYBRID TRANSACTION STRUCTURESEE MORE ON TAXPAGE.COM CANADIAN CONTROLLED PRIVATE CORPORATION: CANADIAN TAX A CCPC has many corporate tax benefits and the biggest one is small business deduction that reduces Part I tax the corporation would otherwise have to pay. Although the general corporate tax rate is 28% after federal abatement, a CCPC only pays a reduced tax rate of 9%. However, the reduced rate only applies to the first $500, 000 of

active

TAXATION OF TESTAMENTARY TRUSTS The taxation of testamentary trusts is a complex area of law that requires detailed analysis and advice from an experienced Canadian tax lawyer. If you are a trustee of a testamentary trust you should consider further steps that could be taken to minimize the trust’s tax liability. If you have a trust included in your last will and

testament

BARE TRUSTS TAX CONSEQUENCES: CANADIAN TAX LAWYER GUIDANCE Introduction: Bare Trusts & Canadian Tax Law. This article aims to provide tax advice to Canadian taxpayers on the concept of a bare trust. In particular, it discusses three key topics concerning a bare-trust relationship—namely, its nature, its relevance for

Canadian tax

TAX FREE CAPITAL DIVIDENDS Tax Free Capital Dividends – Elections and Penalties – A Toronto Tax Lawyer Analysis Capital dividends are a useful method for Canadian private corporations to distribute tax free funds to their shareholders. Corporations can declare these capital dividends which their shareholders can receive tax-free. However, a corporation should be cognizant of the amount in their TAXATION OF SETTLEMENT AMOUNTS PURCHASE & SALE HYBRID TRANSACTION STRUCTURESEE MORE ON TAXPAGE.COM CANADIAN TAXATION OF CROWDFUNDING Canadian Taxation of Crowdfunding—A Canadian Tax Lawyer Analysis What is Crowdfunding? As the name suggests, crowdfunding is a manner of raising funds from a large number of people. Recently, websites such as Kickstarter, Kiva, IndieGoGo, and Microventures have drawn attention to the practice. But crowdfunding has a long history. During the Second World War, Canada TAXATION OF SETTLEMENT AMOUNTS Personal Injury Exception for Settlement Payments. Notably, any amount of a settlement payment for damages with respect to personal injury or death is exempt from tax. This applies to 1) special damages such as out-of-pocket expenses like medical and hospital expenses and loss of both accrued and future earnings; and 2) general damages such as QUALIFYING FOR SMALL BUSINESS DEDUCTION: CANADIAN TAX There are multiple requirements in order to be eligible for the small business deduction. First, the business must be a Canadian-Controlled Private Corporation (“CCPC”). Under subsection 125 (7) of the Income Tax Act, a business will qualify as a CCPC if it meets three criteria: It is a private corporation, meaning its shares are not

traded

REFUNDABLE DIVIDEND TAX ON HAND Refundable dividend tax on hand accumulates in a corporation that earns passive (investment) income until a taxable dividend is paid out to shareholders (thereby being taxed in the shareholder’s hands). The corporation will then recover a percentage of the dividends paid from its RDTOH account. This article will examine some of the key

pieces

A CANADIAN TAX LAWYER’S ANALYSIS OF INCOME TAX ACT The limited partner or specified member will include the gain created by subsection 40 (3.1) arising from a negative adjusted cost base (ACB) in his or her taxable income. Subsection 40 (3.1) deems a disposition to have occurred making the ACB of the partnership interest nil. This deemed disposition prevents the taxpayer from being

double taxed

WHAT HAPPENS WHEN A TFSA HOLDER DIES? Introduction. A Tax-Free Savings Account (“TFSA”) is a registered investment account that allows a taxpayer to participate in eligible investments, and withdraw the account’s investment growth, capital gain and any other earnings on a tax-free basis. The contributions made to a TFSA account are not deductible, neither are any expenses associated with the set up or maintenance of the account. EMPLOYEE STOCK OPTIONS: TAX IMPLICATIONS FOR CANADIAN Employee benefit: The employee’s benefit from exercising the employee stock option is $15 – $10 = $5 – ½ under subsection 110 (1) = $2.50. The employee includes the benefit either in the year she exercised the employee stock option or, if she acquired CCPC shares, in the year that she sells the shares. CHANGES TO THE ELIGIBLE CAPITAL PROPERTY TAX RULES A $500,000 capital dividend may be declared, allowing the operating corporation to pay out an amount of $500,000 on a tax-free basis to the shareholder (s); and. Passive income of $500,000 earned by the operating corporation. This amount will be subject to Part IV tax at a rate of 50.67% – a total tax payable by the corporation of $253,350. CRA SUPER PRIORITY LIENS CRA Super Priority Liens— Exemption for Specified Security Interests. When a given taxpayer does not remit payroll source deductions or GST/HST as required by the ITA and ETA, the deemed tax trust applies to the property of the delinquent taxpayer, property held by secured creditors of the taxpayer and sale proceeds from each

of the foregoing.

CCPC EMPLOYEE STOCK OPTIONS CCPC Employee Stock Options. Employee stock options (“ESO”) are a form of compensation that corporations often grant to certain employees in addition to a regular salary. An ESO grants the holder of the option a right, but not an obligation, to purchase shares

TORONTO TAX LAWYER

CRA Tax Audits. There are over 350,000 tax audit and review actions conducted by the Canada Revenue Agency on a yearly basis. Around 15,000 of these tax audits deal with “cash only” businesses (i.e. the underground economy). Additionally, an estimated 35,000 are tax

shelter audits.

TAXATION OF TESTAMENTARY TRUSTS The taxation of testamentary trusts is a complex area of law that requires detailed analysis and advice from an experienced Canadian tax lawyer. If you are a trustee of a testamentary trust you should consider further steps that could be taken to minimize the trust’s tax liability. If you have a trust included in your last will and

testament

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TAX FREE CAPITAL DIVIDENDS Tax Free Capital Dividends – Elections and Penalties – A Toronto Tax Lawyer Analysis Capital dividends are a useful method for Canadian private corporations to distribute tax free funds to their shareholders. Corporations can declare these capital dividends which their shareholders can receive tax-free. However, a corporation should be cognizant of the amount in their BARE TRUSTS TAX CONSEQUENCES: CANADIAN TAX LAWYER GUIDANCE Introduction: Bare Trusts & Canadian Tax Law. This article aims to provide tax advice to Canadian taxpayers on the concept of a bare trust. In particular, it discusses three key topics concerning a bare-trust relationship—namely, its nature, its relevance for

Canadian tax

TAXATION OF SETTLEMENT AMOUNTS REFUNDABLE DIVIDEND TAX ON HAND Refundable dividend tax on hand accumulates in a corporation that earns passive (investment) income until a taxable dividend is paid out to shareholders (thereby being taxed in the shareholder’s hands). The corporation will then recover a percentage of the dividends paid from its RDTOH account. This article will examine some of the key

pieces

PURCHASE & SALE HYBRID TRANSACTION STRUCTURESEE MORE ON TAXPAGE.COM TAX TREATMENT OF US-OWNED CANADIAN ULC Article IV(7)(b) also denies treaty benefits to a US corporation that receives income from a Canadian ULC. Dividends and royalties paid by a ULC directly to a US corporation are denied treaty benefits, if the ULC is an FTE: the income’s US tax treatment differs from what would have been its tax treatment, if the ULC had not been an FTE. CHANGES TO THE ELIGIBLE CAPITAL PROPERTY TAX RULES A $500,000 capital dividend may be declared, allowing the operating corporation to pay out an amount of $500,000 on a tax-free basis to the shareholder (s); and. Passive income of $500,000 earned by the operating corporation. This amount will be subject to Part IV tax at a rate of 50.67% – a total tax payable by the corporation of $253,350.

TORONTO TAX LAWYER

CRA Tax Audits. There are over 350,000 tax audit and review actions conducted by the Canada Revenue Agency on a yearly basis. Around 15,000 of these tax audits deal with “cash only” businesses (i.e. the underground economy). Additionally, an estimated 35,000 are tax

shelter audits.

TAXATION OF TESTAMENTARY TRUSTS The taxation of testamentary trusts is a complex area of law that requires detailed analysis and advice from an experienced Canadian tax lawyer. If you are a trustee of a testamentary trust you should consider further steps that could be taken to minimize the trust’s tax liability. If you have a trust included in your last will and

testament

SUCCESSION WILL, ESTATE AND TAX PLANNING ONTARIOSEE MORE ON

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TAX FREE CAPITAL DIVIDENDS Tax Free Capital Dividends – Elections and Penalties – A Toronto Tax Lawyer Analysis Capital dividends are a useful method for Canadian private corporations to distribute tax free funds to their shareholders. Corporations can declare these capital dividends which their shareholders can receive tax-free. However, a corporation should be cognizant of the amount in their BARE TRUSTS TAX CONSEQUENCES: CANADIAN TAX LAWYER GUIDANCE Introduction: Bare Trusts & Canadian Tax Law. This article aims to provide tax advice to Canadian taxpayers on the concept of a bare trust. In particular, it discusses three key topics concerning a bare-trust relationship—namely, its nature, its relevance for

Canadian tax

TAXATION OF SETTLEMENT AMOUNTS REFUNDABLE DIVIDEND TAX ON HAND Refundable dividend tax on hand accumulates in a corporation that earns passive (investment) income until a taxable dividend is paid out to shareholders (thereby being taxed in the shareholder’s hands). The corporation will then recover a percentage of the dividends paid from its RDTOH account. This article will examine some of the key

pieces

PURCHASE & SALE HYBRID TRANSACTION STRUCTURESEE MORE ON TAXPAGE.COM TAX TREATMENT OF US-OWNED CANADIAN ULC Article IV(7)(b) also denies treaty benefits to a US corporation that receives income from a Canadian ULC. Dividends and royalties paid by a ULC directly to a US corporation are denied treaty benefits, if the ULC is an FTE: the income’s US tax treatment differs from what would have been its tax treatment, if the ULC had not been an FTE. CHANGES TO THE ELIGIBLE CAPITAL PROPERTY TAX RULES A $500,000 capital dividend may be declared, allowing the operating corporation to pay out an amount of $500,000 on a tax-free basis to the shareholder (s); and. Passive income of $500,000 earned by the operating corporation. This amount will be subject to Part IV tax at a rate of 50.67% – a total tax payable by the corporation of $253,350.

TORONTO TAX LAWYER

CRA Tax Audits. There are over 350,000 tax audit and review actions conducted by the Canada Revenue Agency on a yearly basis. Around 15,000 of these tax audits deal with “cash only” businesses (i.e. the underground economy). Additionally, an estimated 35,000 are tax

shelter audits.

REFUNDABLE DIVIDEND TAX ON HAND Refundable dividend tax on hand accumulates in a corporation that earns passive (investment) income until a taxable dividend is paid out to shareholders (thereby being taxed in the shareholder’s hands). The corporation will then recover a percentage of the dividends paid from its RDTOH account. This article will examine some of the key

pieces

TAX TREATY RESIDENCE DETERMINATION: CANADIAN TAX LAWYER A residence determination is a form, or when carried out by our experienced Canadian tax lawyers, a form and accompanying explanatory letter, filed with the Canada Revenue Agency to receive a non-binding opinion from the Canada Revenue Agency about the taxpayer’s residence. A residence memorandum is legal analysis drafted by an

expert

LEADERSHIP TEAM

Founding Canadian tax lawyer, David J. Rotfleisch, is a Certified Specialist in Taxation expert in the realm of Canadian income tax law. You might say that income tax is David’s passion for David is not only a lawyer, he is a chartered professional accountant and has completed the CICA in-depth tax course. He has helped start-up businesses, resident and non-resident business owners and CEBA AUDIT SERVICES: CANADIAN TAX LAWYER’S TAX GUIDANCE The following is a summary of the CEBA eligibility criteria: The borrower is a Canadian operating business in operation as of March 1, 2020; The borrower has a federal tax registration; The total employment income paid by the borrower in the 2019 calendar year was between $20,000 and $1,500,000. For applicants who paid $20,000 or

less in total

KIDDIE TAX ATTRIBUTION RULES Kiddie Tax Attribution Rules. The “kiddie tax” in section 120.4 of the Canadian Income Tax Act generally applies to income of a child under 18 attributable to dividends or shareholder appropriations from a private corporation designed to split income. The kiddie tax is not applicable to capital gains. Prior to the so called “Kiddie Tax BUTTERFLY TRANSACTIONS Butterfly transactions are used when shareholders in a business are going their separate ways. It’s a tax-free way of dividing assets between parties or between two companies in the same corporation. These transactions are essentially rollovers completed under section 85 of the Income Tax Act. Parties involved in butterfly transactions

must

TAXATION OF SHAREHOLDERS: THE BASIC DEEMED-DIVIDEND TAX As a result, the shareholder receives a deemed dividend of $1 ($8 distribution minus $7 PUC reduction). The shareholder’s ACB for the share is reduced by $7. So, the shareholder owns a share with an ACB of $3 and PUC of $3. So, subsection 84 (4) permits a private corporation to distribute a tax-free return of capital so long as the TAX IMPLICATIONS OF SEPARATED COUPLES UNDER THE SAME ROOF The Tax Implications of Separated Couples Once They Move to Different Locations. If the two individuals move away from each other for more than 90 days, the Canada Revenue Agency will consider them as separated effective after the 90 th date. At this point, it’s the responsibility of the individuals to change their marital status by

either

TRANSFERRING FOREIGN PENSION TO RRSP: A CANADIAN TAX Paragraph 60 (j) effectively allows a Canadian tax resident to cash out a foreign pension and transfer the proceeds to an RRSP on a tax-deferred basis. The taxpayer still reports the foreign pension as income, but, if the taxpayer satisfies the conditions of subparagraphs 60 (j) (i), 60 (j) (iii), and 60 (j) (iv), the taxpayer may fully

deduct

FREE INCOME TAX ADVICE ON PHONE We offer a FREE 10 MINUTE INCOME TAX CONSULTATION with one of our students. We will identify your tax problem and advise you if you need assistance from a tax lawyer to solve it and if so we will suggest a one hour consultation with one of our lawyers, the fees if you wish to consult and a rough estimate of the legal fees if you choose to retain us.

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TAX PROBLEMS? WE FIGHT CRA RETAIN US AND SLEEP AT NIGHT TAX PLANNING TO REDUCE TAXES REORGANIZATION, WILLS & ESTATE PLANNING TAX LAWYERS - OVER 25 YEARS OF EXPERIENCE WE CAN HELP WITH ALL TAX ISSUES

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TAX PLANNING

Tax planning for business or for individuals and families is an ongoing process to reduce the overall taxes owing by the business and ultimately by the owners and family. When setting up and running a

business a team

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TAX AUDITS, PROBLEMS & REPRESENTATION A CRA audit is the start of the tax investigation and a Canadian taxpayer needs professional representation from the start. Never speak to CRA by yourself. Always have your Canadian tax lawyer deal with CRA

on your behalf.

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VOLUNTARY DISCLOSURE The voluntary disclosure program allows you to avoid prosecution or penalties for unreported income or offshore assets by having one of our Canadian tax amnesty lawyers approach CRA on your behalf before

they approach you.

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UNPAID TAX DEBT AND CRA GARNISHMENT The CRA can send a garnishee notice to your employer or can even seize your bank accounts if you owe them taxes. In many cases you will find yourself bankrupted while making payment arrangements.

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FIGHT CRA

CRA can and does lien salary and seize assets and bank accounts without a court order. CRA can and does show up at your home and place of business. Our top Canadian tax lawyers will protect your rights and

will fight for you.

TAXPAYER RELIEF (FAIRNESS APPLICATION) In some limited circumstances CRA will eliminate or reduce interest or penalties that they have charged you. A taxpayer relief application (fairness application) can be submitted when circumstances out of your control resulted in penalties and interest owing to the Canadian tax department. Read more

TAX COURT APPEALS

Once a Notice of Confirmation from the Canada Revenue Agency confirming the audit assessment is received, the next level of disputing a tax assessment/reassessment is to have your Canadian Tax Litigation Lawyer file a Notice of Appeal with the Tax Court of

Canada.

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__ __TAX CRIMES - TAX EVASION, TAX FRAUD, UNFILED TAX RETURNS Did you know that you can go to jail for tax crimes, including unfiled tax returns? If CRA has not approached you then you may qualify for the voluntary disclosure program .If CRA has started an investigation, or you been charged with a tax crime such as tax evasion or have received a summons (prosecution) for unfiled tax returns our experienced Canadian tax litigation lawyers can help you.

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Tax Shelters are generally investments that have as a main or secondary purpose the reduction of taxes, and are often challenged by CRA. The Canadian tax department has been warning about charity tax shelters for years, and has tried various approaches to shutting down the charity tax shelter industry.Read more __ __ CRA BACK TAXES OWING COLLECTION Taxpayers are often overwhelmed by a tax assessment or a Tax Statement of Account that shows a balance owing that is impossible to pay. One common reaction is to ignore it since you can’t afford to pay. Read

more

__ __ EMPLOYEE STOCK OPTIONS Stock options are usually granted to employees to give them more motivation in helping with the success of the business. They are sometimes called golden handcuffs. The Income Tax Act encourages employee stock options by granting them favorable tax treatment. Read

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FAQ

__ __ DO I NEED A LAWYER FOR A TAX AUDIT? Lawyers Providedifferent expertise than accountants. If there are legal issues such as your entitlement to a deduction or possible penalties or criminal charges you need a lawyer to help you with your tax audit. You will also often need an accountant to work with your tax lawyer.You also need a tax lawyer to provide you with Solicitor client privilege to prevent CRA from seizing documents from you or from your Accountant. __ __ WHEN DO YOU NEED A TAX LAWYER? You need a tax lawyer whenever CRA is threatening you with penalties or tax prosecution. You should also be represented by a tax lawyer Whenever there are legal tax issues in dispute such as a limitation period or right to a deduction. If you want to reduce your taxes owing through tax planning you should also retain a tax lawyer area Finally, you need a tax lawyer to ensure solicitor client privilegeTo prevent CRA from seizing documents from you or from your accountant. __ __HOW DO I FIND THE BEST TAX LAWYER IN TORONTO? You can find the name of a tax lawyer through the Internet or through referrals. Once you find someone it's important to do your due diligence to ensure that you have the best lawyer possible and that the lawyer fits with your needs. Consider years of experience; types of experience; knowledge as indicated by publications; testimonials. SUBSCRIBE TO OUR NEWSLETTER GET THE LATEST TAX NEWS FROM US

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SUBSCRIBE TO OUR NEWSLETTER * Net Worth Assessments * Third Party Assessments * Tax Problems & Tax Representation

* Tax Minimization

If you have not filed your Canadian tax returns, or if you have filed them and CRA believes that you have not reported all of your income, they may issue a new worth assessment

. They take two

financial snapshots, one at the start of the audit period and one at the end. They add your reported income and expenditures to the opening financial position and subtract loans. If the amount is less than your closing net worth they will assess you for tax, penalties and interest on the difference. Net worth assessments require an understanding of the accounting behind the CRA calculations and the proper inclusions and exclusions from the opening and closing balances. Our firm has a track record of fighting these assessments. You may be liable for someone else's taxes. CRA can assess Canadian taxpayers under section 160 of the Income Tax Act for the tax liability of another party. This occurs in situations where a taxpayer who owes taxes transfers assets such as a house or money to a related party, usually a relative such as a spouse or child. CRA will issue an assessment against the relative who receives the property for the taxes owing by the transferor. CRA collections officers will then proceed to enforce the taxes owing, and will often lien the house. The s.160 assessment can be challenged by filing a Notice of Objection within 30 days. The taxes owing by the asset transferor can be challenged as part of the Objection process.

INCOME TAX DEBT

A CRA tax debt has to be addressed immediately. If it is ignored a CRA collections officer will commence tax enforcement actions. This means your bank account will be seized, your wages or accounts receivable or rents will be garnished, and your house may have a lien registered.Read more TAX AUDIT ASSISTANCE There are over 350,000 audit and review actions conducted by the Canada Revenue Agency on a yearly basis. Around 15,000 of these audits deal with “cash only” businesses (i.e. the underground economy). Additionally, an estimated 35,000 are tax shelter audits.Read more TAX PLANNING – INCOME SPLITTING A Canadian taxpayer’s income tax bracket and therefore the income tax liability depends on the absolute amount of the taxpayer’s income because the higher the income the higher the income tax bracket and the percentage of income tax paid. Income splitting is a tax planning strategy whereby one taxpayer transfers a portion of his/her own income to another taxpayer who is taxed at a lower tax rate. There are various income splitting techniques that can be used.Read more INCOME SPLITTING TAX PLANNING- SALARIES A small business owner can often income split with a spouse by employing the spouse in the business as a T4 employee or by having the spouse own shares of the corporation and receive dividends. Any salary paid must be reasonable and supported by the actual work done. A written employment agreement is very advisable. If the spouse or children are going to own shares of the business, care must be taken to avoid the income tax attribution rules that attribute income or capital gains on the property back to the spouse who originally owned the assets.Read more



WHAT OUR CLIENTS ARE SAYING? When I received a Notice of Assessment from the Canada Revenue Agency saying I owed an additional $99.769.24 in taxes, I was shocked and I had no idea where to turn. After searching on the internet, I quickly found the top ranked tax law firm of Rotfleisch and Samulovitch P.C. David Rotfleisch, CPA, J.D. listened to me explain my situation, and quickly filed a Notice of Objection on my behalf. They were successful in eliminating the extra amount CRA claimed I owed, and they even got rid of the interest and late filing penalties. My tax liabilities went from $99,769.24 all the way down to $4,040. I love that my case was handled quickly and in a way designed to keep costs low, and I could not be happier to recommend the firm to anyone with tax issues. I.I., Toronto - Client David J. Rotfleisch, CPA, JD was my tax and business lawyer in a difficult share sale transaction. He advised me on the income tax and business aspects, handled long and difficult negotiations and successfully closed the share sale. He was very “hands-on” with the deal and was able to resolve matters to my entire satisfaction. I recommend him for any business or tax matters. Michael Bargman, Toronto, Tel Aviv - Client David J. Rotfleisch, CPA, JD, represented me in the Tax Court of Canada and in the Federal Court of Appeal . My income tax case went back to the 1980s but was only heard in 2008 and 2009 partially due to the complexity. It involved securities hedging and complex business, complex law and complex accounting issues. I was fortunate to find a lawyer who even understood the business aspect. The organization of David’s firm enabled this successful case to be completed in a cost effective manner, which I doubt the larger law firms could have achieved. I am delighted with his representation and would recommend him without hesitation. Russ Witt, Toronto - Client I first met David Rotfleisch when he acted for the vendor of a business I bought, Richards-Wilcox, over 20 years ago. My partner and I were so impressed by him that once the deal was complete we retained him as our tax and business lawyer. He has acted for us on all tax and corporate matters since then, including the sale of our successful garage door business to Raynor in the US and has represented Raynor on the Canadian aspects of various transborder transactions. If you need a tax or business lawyer, David has a broad grasp of tax and business law and is helpful and responsive. Ray Friesen Raynor Canada, Mississauga - Client I am a serial entrepreneur, having been involved in different businesses over the years. David J. Rotfleisch has been my tax and business lawyer for over 20 years. He has helped me with complex income tax and GST/HST issues over the years, including tax prosecutions and a subsequent voluntary disclosure that was successfully submitted. I find him to be very experienced and knowledgeable and able to explain complex issues in very clear language. He has a passion for solving business and tax problems, not accepting CRA excesses and attacking CRA's abuses. David's professionalism , attention to detail and unrelenting persuit of justice for the"little guy" has given me comfort while the CRA wolves were pacing at the door. E.P., Mississauga, Ont - Client I own Multimedia Lighting & Electric Ltd, an electrical contractor that specializes in large display signs. David Rotfleisch has been my tax and business lawyer and advisor since I started in business more than 15 years ago. He is great at planning to reduce my taxes and keeping me out of any trouble with CRA. His planning and advice is clever and to the point and I rely on him without hesitation. Doug Hishon, Jr. Multimedia Lighting & Electric Ltd, Toronto, Ont -

Client

I first met David Rotfleisch when he acted for the vendor of a business I bought, Richards-Wilcox, over 20 years ago. My partner and I were so impressed by him that once the deal was complete we retained him as our tax and business lawyer. He has acted for us on all tax and corporate matters since then, including the sale of our successful garage door business to Raynor in the US and has represented Raynor on the Canadian aspects of various transborder transactions. If you need a tax or business lawyer, David has a broad grasp of tax and business law and is helpful and responsive. Ray Friesen Raynor Canada, Mississauga - Client I own Hometown Electric, an electrical contractor that specializes in large display signs. David Rotfleisch has been my tax and business lawyer and advisor since I started in business more than 15 years ago. He is great at planning to reduce my taxes and keeping me out of any trouble with CRA. His planning and advice is clever and to the point and I rely on him without hesitation. Doug Hishon, Jr. Hometown Electric, Toronto, Ont - Client I have used David Rotfleisch as my business and tax lawyer for over 20 years. I own and publish Canadian Homes & Cottages Magazine, and David has been our go to lawyer for over 20 years. He has handled all of my business and personal tax issues as well as my will and estate planning. David and his team are very good at anticipating and handling issues before they develop into problems, and in solving unexpected problems. I would not think of going to any other lawyer. Stephen Griffin, Canadian Homes and Cottages Magazine, Mississauga,

Ontario - Publisher

Dealing with adversarial tax issues is much like a root canal ,a painful but essential process to save the tooth. A skilled and confident Dentist is essential to the exercise. David Rotfleisch and his staff provided me with a concise and timely roadmap through the Voluntary Disclosure Process. There are many people touting their connections and expertise in the media. David and his staff produce results in an understated and professional manner. Choose your advisor carefully and make it Rotfliesch & Samulovitch. Dennis, Aurora, Ontario - Client

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WHAT OTHER PROFESSIONALS ARE SAYING? I run a professional CPA practice with staff in Toronto, Canada and Texas, USA and have been dealing with David Rotfleisch's tax law firm for over 15 years. David and I have worked on many different CRA and business files over the years, including voluntary disclosures, audits and appeals and the purchase and sale of businesses. He provides practical and timely tax and business advice. I refer all of my clients who need a Canadian business or tax lawyer to David. Sanjay Sen CPA (TX), CA (India), CGMA (UK);Toronto, Ont and San Antonio, Texas, June 2015 - Chartered Accountant I am a chartered professional accountant and a partner with the national accounting firm of Collins Barrow. I have worked with David Rotfleisch on hundreds of client files over the last 15 years. He is my most accessible tax lawyer and the one that I frequently go to, especially since he also has an accounting degree. He understands the accounting side of the issues as well as the tax and business law considerations. He deals with tax problems in a direct and cost effective way. I strongly recommend him to anyone in need of a Canadian tax lawyer. Larry Rich, FCPA, FCA, TEP, Toronto - Chartered Professional

Accountant

I am a long time professional bookkeeper. From time to time my clients need a Canadian tax or business lawyer for will or tax planning or have problems with CRA and have to file a Notice of Objection or Appeal to Tax Court, or have unfiled income tax returns and have to submit a Voluntary Disclosure. I have been working exclusively with David Rotfleisch's tax law firm for over 5 years. He and his staff are knowledgeable in tax and corporate matters, responsive, effective and provide cost effective tax solutions. I continue to refer clients to him and would recommend him to anyone who has need of his services. Gail Carver, Bookkeeping in the Beach, Toronto, Ontario - Bookkeeper As a tax CPA/CA I am always working with Canadian income tax lawyers to implement transactions or reorganizations, to provide income tax opinions for private or public deals and to carry out income tax litigation. I have been working with David Rotfleisch and his tax law firm for over 15 years. He has assisted me and my clients on all aspects of tax law. I enjoy working with him, he responds to phone calls and emails as soon as they are sent, he promptly reviews and comments on documents. I have only good things to say about him and do not hesitate to refer him to my clients. Michael Fromstein, CA, Integrated Tax Specialist Services, Toronto -

Tax CPA/CA

As a Partner at Sloan Partners LLP, Chartered Professional Accountants I am heavily involved in tax planning and tax compliance matters for a diverse client base. To assist us in providing the best service to our clients, we use lawyers to help formalize and implement income tax planning arrangements. In those cases where our clients are challenged by CRA, we need a lawyer skilled in tax litigation to defend their positions. My relationship with David J. Rotfleisch goes back almost 20 years. David has always been available to discuss concepts and issues and to provide invaluable assistance to clients. Although clients always come first, we also enjoy chatting about photography since we’re both serious about that too. Jerry Paskowitz, CPA, CA, CMC, Partner Sloan Partners LLP - Chartered Professional Accountant

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