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...
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: 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...