Publications

$1.7M for CRA’s “Malicious Prosecution” Set Aside on Appeal

The British Columbia Court of Appeal (the “BCCA”) reversed (the “Decision”) a landmark decision (the “Lower Court Decision”) that had awarded a B.C. couple (the…

Bribery and Corruption in International Business

The SNC-Lavalin affair has dominated the Canadian news media for two months without complete revelation of what really happened. All that we know for sure…

Fines and Penalties

Section 67.6: “In computing income, no deduction shall be made in respect of any amount that is a fine or penalty (other than a prescribed…

CRA’s Initial Cryptocurrency Audits are Likely First of Many

The Canada Revenue Agency (the “CRA”) appears to be targeting users of bitcoin and other cryptocurrencies for audit, according to a Forbes online article (the…

Paradise Papers, New VDP Not Government’s Panacea in 2019

The Canada Revenue Agency (the “CRA”) has launched roughly 100 audits into taxpayers named in the Paradise Papers offshore tax leak, according to documents tabled…

CRA Crackdown Eyes Toronto and Vancouver Property Sales: Worth $600 Million in Lost Revenue

The CRA is focussed on recovering lost revenue in the real estate market. In particular, it is targeting home sales in Vancouver and Toronto. On…

Uber’s Tax Woes Signal Gig Economy is the Next Frontier in CRA’s Tax Collection Efforts

Uber wants its users, its drivers and particularly the Canada Revenue Agency (the “CRA”) to agree that it does not provide “rides” to its “customers”….

Restaurant Owners Who Buy from The Beer Store Will Face Increased CRA Scrutiny

Ontario restaurant and bar owners are likely the latest target of the Canada Revenue Agency’s (the “CRA”) effort to audit unreported or under-reported income tax…

The Three Steps of GAAR

Please see Vern Krishna’s latest article for the Taxnet Pro: Tax Disputes & Resolution Centre titled, “The Three Steps of GAAR” where he discusses the general…

A Review of Rectification in a Post-Fairmont World

Please see David Piccolo’s latest article for the September issue of the Tax Advocate titled, “A Review of Rectification in a Post-Fairmont World,” where he discusses…

Vern Krishna in the 2019 Edition of The Best Lawyers™ in Canada

We are very proud to announce that once again our colleague Professor Vern Krishna was recognized by The Best Lawyers™ in Canada for his work in: Appellate…

Taxation of cryptocurrency transactions

With all the excitement concerning the price of cryptocurrencies, individuals and businesses have glossed over the fact that every cryptocurrency transaction is a taxable event…

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