Arbitrage Betting and Prediction Markets in Canada: Who This Guide Is For This guide is written for two distinct audiences: casual participants who occasionally place opposing bets across platforms to capture a pricing gap, and organized arbitrage traders who systematically scan multiple bookmakers or prediction markets, use dedicated tools,...
Overview: Significant gross negligence penalties against a taxpayer who blindly relied on a fraudulent tax preparation scheme to claim fictitious business losses This case centers on the imposition of gross negligence penalties under subsection 163(2) of the Income Tax Act against the Appellant, Attila John Burzuk. The penalties were...
CRA Denied Your Business Loss? Immediate Steps for Entrepreneurs and Investors If the CRA denied your business losses, you are likely facing increased tax liability and uncertainty about how to dispute the CRA’s position. This situation typically arises following a tax audit or review, where the CRA concludes that...
Overview: CRA Reassessment of $36 Million in Feasibility Study Deductions — Deductibility, Transfer Pricing, and Part XIII Withholding Tax In ExxonMobil Canada Resources Company v. The King, 2026 TCC 42 , the Tax Court of Canada ruled that ExxonMobil Canada Resources Company (“ExxonMobil Canada”) could deduct more than...
Overview: The Capital vs. Income Distinction and Why It Costs Taxpayers Millions One of the most consequential and frequently litigated questions in Canadian real estate tax law is whether the proceeds from the disposition of real property are taxable as a capital gain or as ordinary business income. The...
CRA Artificial Intelligence and Tax Audit Risk: Overview for Canadian Taxpayers Artificial intelligence is no longer a future consideration for Canadian taxpayers. It’s already embedded in how the Canada Revenue Agency selects returns for tax audit, enforces compliance, and administers penalties. The CRA actively deploys machine learning algorithms, predictive...
Overview: When the CRA’s Conduct Increases the Cost of Tax Litigation In Canada v. Marine Atlantic, the Federal Court of Appeal considered an important issue about court costs, fairness in litigation, and the conduct expected from the CRA during tax disputes. The decision in Canada v. Marine Atlantic is...
Overview – A Toronto Business Owner, the COVID-19 Pandemic, and the Canada Emergency Rent Subsidy Program Milne v The King is a 2026 decision from the Tax Court of Canada regarding taxpayer eligibility for the Canada Emergency Rent Subsidy (“CERS”) program in which the taxpayer operated a business out of...
The recent decision in C&W Offshore Ltd. v. HMK, 2026 TCC 40, serves as a stark reminder to Canadian businesses of the rigorous obligations imposed by Part XIII of the Income Tax Act (ITA) when dealing with non-resident suppliers. The case centered on two primary issues: first, whether rental...
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...