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...
Overview: From Tax Request to Court Penalty: What Went Wrong This case concerns the enforcement powers of the Canada Revenue Agency (CRA) and the consequences of failing to comply with a court order under the Income Tax Act. The Federal Court had to decide how to penalize a company...
Introduction: Rising CRA Real Estate Tax Audit Risk in Canada CRA real estate tax audits have entered a new phase of sophistication, with the Agency increasingly relying on third-party data sources — most notably MLS listings — to identify potential non-compliance. This shift significantly heightens exposure for homeowners, renovators,...
Introduction: Not every case needs a trial: how judges handle baseless arguments and claims The case of Blake v. Ahmed (2025 BCCA 384) concerns a dispute between a taxpayer and government authorities over the collection of unpaid taxes. The British Columbia Court of Appeal was asked to determine whether...
Overview – The Burden to Challenge the Factual Basis of the Tax Reassessment In 2251102 Ontario Inc. v. The King, 2026 TCC 61, the Tax Court of Canada considered whether a taxpayer can successfully challenge a tax reassessment based on a net worth analysis where the CRA has relied...
Introduction: A dispute over wine donations and the rules of charitable tax credits. The case of Ebert v. The King (2023 TCC 49) was decided by the Tax Court of Canada in April 2023. The case involved three taxpayers—Irving Ebert, Richard Herman, and P. Philippe DesRosiers—who had donated bottles...
Family Trust Planning and the Hidden Role of Exempt Foreign Trusts Canada’s non-resident trust regime under section 94 of the Income Tax Act is one of the most significant anti-deferral frameworks in Canadian international tax law. Following the 2007 legislative tax reforms, the provision greatly expanded Canada’s ability to...
Introduction: CRA Expands Trust Reporting Requirements to Increase Transparency Canada’s trust reporting framework has undergone significant reform in recent years as part of broader efforts to improve tax transparency and prevent tax avoidance through undisclosed beneficial ownership arrangements. The Canada Revenue Agency (CRA) now requires many trusts to provide...