Archive for Author: taxlaw

Canadian bank account freeze and tax garnishment concept illustrating CRA Requirement to Pay enforcement.

CRA Requirement to Pay: When Can a Third Party Become Personally Liable for Another Taxpayer’s Tax Debt? A Canadian Tax Lawyer’s Analysis of Dejifasanya v. The King

Contents: CRA Requirement to Pay: When Can a Third Party Become Personally Liable for Another Taxpayer’s Tax Debt? A Canadian Tax Lawyer’s Analysis of Dejifasanya v. The King Overview: When a CRA Requirement to Pay Can Turn Someone Else’s Tax Debt Into Your Own Liability How Does a CRA...

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Canada’s Foreign Influence Transparency Registry: The Income Tax and GST/HST Consequences Registering Organizations Are Missing

Overview: Tax Consequences of Canada’s New Foreign Influence Registry Canada’s Foreign Influence Transparency and Accountability Act came into force on August 4, 2026, creating a public registry overseen by the Office of the Foreign Influence Commissioner. Most of the commentary since then has focused on who is caught by...

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Robinson v Canada: Federal Court Sets Strict Mutual Agreement Procedure (MAP) Deadline in Reassessment Deals with CRA

Overview: Robinson v Canada and the Three-Year MAP Deadline Under the Canada-UK Tax Treaty Robinson v Canada (Attorney General), 2026 FC 854 (Federal Court File No. T-1567-22) is a significant Federal Court decision for taxpayers, accountants, and advisors managing cross-border residence disputes. The case confirms that the three-year...

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