Overview: How the CRA may deal with incomplete or unreliable tax records The case of Karlozian v. The King deals with an important issue in Canadian tax law: how the Canada Revenue Agency (CRA) determines unreported income when a taxpayer’s records are incomplete or unreliable. The case also examines...
Overview of Canadian Regulatory Framework for Foreign Exchange Businesses Foreign exchange bureaus operating in Canada are subject to a comprehensive compliance regime under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), administered primarily by the Financial Transactions and Reports Analysis Centre of Canada, alongside tax reporting...
Overview: GAAR, Tax Avoidance, and the Tax Court of Canada’s Ongoing Interpretation The decision in Foix v. The King, 2026 TCC 63, represents a significant Tax Court of Canada ruling on the application of the General Anti-Avoidance Rule (GAAR) in the context of sophisticated tax planning. The case provides...