Media & News
Plain-English Canadian tax writing.
Articles for taxpayers, accountants, and lawyers — written by the lawyers who handle the cases.
May 22, 2026
May 19, 2026
May 14, 2026
May 13, 2026
May 12, 2026
- CRA Voluntary Disclosure Program: Eligibility, Step by Step
- How to File a Notice of Objection (Step by Step)
- Audit Defence vs Voluntary Disclosure vs Objection & Appeal: Choosing Your CRA Route
- Family Trusts in Canadian Tax & Estate Planning
- Gross Negligence Penalties (s.163(2)): How They're Applied and How They're Challenged
- CRA Audit Readiness Checklist
- NFTs, Staking, Mining & DeFi: Canadian Tax Treatment
- GST/HST Audits: Common Triggers and How to Defend Them
- Common Tax Mistakes New Businesses Make — and How to Avoid Them
- UAE Holding Companies and Treaty Planning: Substance, the Principal Purpose Test, and the Canada–UAE Treaty
May 8, 2026
May 7, 2026
May 6, 2026
May 5, 2026
- Offshore Assets & T1135: Coming Clean Through the VDP
- Director's Liability for Unremitted Source Deductions & GST/HST (s.227.1)
- Case Study: Defending a Director Against a Section 227.1 Liability Assessment
- Settling a Tax Court Appeal Before Trial
- How to Present Evidence and Witnesses at the Tax Court (Self-Rep Guide)
April 28, 2026
April 22, 2026
April 21, 2026
April 20, 2026
April 16, 2026
April 15, 2026
April 14, 2026
- Net Worth Audits: How the CRA Builds an Indirect-Income Assessment
- Crypto and the CRA: Audit Risks, Exchange Data Requests, and Record-Keeping
- Business Records That Survive an Audit: What to Keep, and for How Long
- UAE Free Zones and Qualifying Free Zone Person (QFZP) Status: How the 0% Rate Actually Works
- CRA Liens and Charges on Your Property: How They Arise and How to Deal With Them
April 9, 2026
- Estate Freeze Mechanics: Section 86 vs Section 85 vs Section 51
- Buying U.S. Real Estate as a Canadian: Ownership Structures and Tax
- When Should an Accountant Refer a Client to a Tax Lawyer?
- Denied Input Tax Credits: Why the CRA Disallows ITCs and How to Respond
- Tax Lawyer vs Accountant for a CRA Dispute
April 8, 2026
April 7, 2026
April 1, 2026
March 31, 2026
March 30, 2026
March 26, 2026
March 25, 2026
March 24, 2026
March 23, 2026
March 20, 2026
March 18, 2026
March 16, 2026
March 12, 2026
March 11, 2026
March 10, 2026
March 6, 2026
March 4, 2026
- Cross-Border Estate Planning When One Spouse is American
- Case Study: Defending a CRA Audit That Alleged Unreported Income and Disallowed Expenses
- Inside CRA Collections: The Officer, the Powers, and How to Negotiate
- Owner-Manager Tax Savings: Corporations, Family Wages, and Income Splitting
- Testamentary Trusts, Henson Trusts & Blended-Family Planning
- Selling Your Pharmacy: Maximizing Value and Minimizing Tax
- What Happens If You Don't File Your Taxes in Canada
- Tax Planning for High-Net-Worth Families
March 3, 2026
February 26, 2026
February 25, 2026
February 24, 2026
February 18, 2026
February 17, 2026
February 12, 2026
February 11, 2026
February 10, 2026
- The Estate Freeze: Locking In Today's Value for Tomorrow's Tax
- What Makes a Will Valid in Canada
- Pharmacy Succession Planning: Corporate Reorganizations That Preserve Value
- Choosing a Business Structure: Sole Proprietorship, Partnership, or Corporation
- The Tax Court Informal Procedure, Explained
- How to Represent Yourself at the Tax Court of Canada (Informal Procedure)
- GST/HST Appeals at the Tax Court of Canada
- Tax Planning for Business Owners: A Practical Guide
August 1, 2023
September 7, 2021
- Directors’ Liability and Section 160 Assessments
- Tax Guidance with Respect to Real Estate Property for Canadian Non-Residents
- Section 116: A Purchaser's Liability in a Real Estate Transaction When Buying from a Potential Non-resident
- Conditions of a Valid Voluntary Disclosure Program Application
- Voluntary Disclosure Program – Guidance from a Canadian Tax Lawyer
August 18, 2021
July 25, 2021
July 5, 2021
January 28, 2021
January 25, 2021
January 21, 2021
December 7, 2020
November 2, 2020
September 29, 2020
March 30, 2020
November 22, 2019
October 10, 2019
April 9, 2019
April 8, 2019
August 3, 2018
June 18, 2018
April 24, 2018
January 13, 2018
May 12, 2016
- Vehicle Expenses
- Transfers of Property while Having a Tax Debt
- Transfer Pricing
- Tax Residency
- GST/HST Small Supplier
- Small Business Deduction
- Qualified Small Business Corporation Shares
- Qualified Fishing Property
- Principal Residence Exemption (PRE)
- Precious Metals
- Personal Services Business
- Permanent Establishment
- Lifetime Capital Gains Exemption
- Income Splitting Through Loans
- Illegal Income
- Gross Negligence Penalties
- Gifts and Inheritances
- General Anti-Avoidance Rule (GAAR)
- Fraudulent Filing
- Directors Liabilities
- Change in Use
- Allowable Business Investment Loss
- Active Business Income
- Canadian Controlled Private Corporation
- Attribution Rules
- Employee v. IC
- Vehicle Expenses - Keeping a Log
- Qualified Farm Property
- Non-Taxable Income
May 10, 2016
March 22, 2016
February 25, 2016
December 2, 2015
November 6, 2015
October 29, 2015
October 27, 2015
September 14, 2015
September 10, 2015
September 8, 2015
September 1, 2015
August 26, 2015
August 17, 2015
August 5, 2015
July 24, 2015
July 21, 2015
July 15, 2015
July 8, 2015
July 6, 2015
June 25, 2015
June 18, 2015
June 4, 2015
April 24, 2015
April 10, 2015
April 9, 2015
April 7, 2015
April 1, 2015
March 31, 2015
March 25, 2015
March 18, 2015
March 16, 2015
March 10, 2015
March 9, 2015
June 28, 2013
April 24, 2013
April 23, 2013
February 26, 2013
February 20, 2013
February 13, 2013
October 12, 2012
November 14, 2011
The Estate Freeze, Explained
An estate freeze caps the tax on a business owner's death at today's value and lets future growth accrue to the next generation or a family trust. Here is what a freeze is, when it makes sense, and how it is built.
Read more →Owner-Manager Remuneration: Salary vs. Dividends
Salary or dividends? The classic owner-manager question turns on integration, CPP, RRSP room, and your own cash needs. Here is how each option works, what it costs, and when each one wins.
Read more →The CRA Audit Process, Step by Step
A CRA audit is a structured, evidence-based review of one or more tax years. This guide walks through the full lifecycle — from file selection and the first letter to the proposal letter, reassessment, and your objection rights — with realistic timelines.
Read more →Amalgamations, Wind-Ups, and Corporate Simplification
Corporate groups accumulate dormant companies, redundant holdcos, and tangled cross-holdings over time. Section 87 amalgamations and section 88 wind-ups are the two main tools for simplifying them — without losing the tax attributes that matter.
Read more →Talking to a Justice Canada Lawyer About Settlement (Self-Represented)
How settlement works when you represent yourself at the Tax Court: who the Crown lawyer is, what can and cannot be settled, how to negotiate on a principled basis, and what minutes of settlement mean.
Read more →Reducing Probate Fees: Multiple Wills, Trusts & Assets That Pass Outside the Will
Probate fees are charged on the value of assets passing through a probated will. Multiple wills, jointly held assets, named beneficiaries, and trusts can each move value outside that calculation — if the planning is done carefully.
Read more →What Makes a Tax Court Appeal Succeed
Tax Court appeals are not won on clever arguments alone. Evidence, credibility, a clearly framed legal issue, and an honest assessment of the case before it is filed are what separate the appeals that succeed from the ones that should have settled.
Read more →Case Study: An Estate Freeze and Section 85 Reorganization for a Family Business
An illustrative planning scenario: a family-business owner used an estate freeze and a section 85 rollover to cap future tax at death and bring the next generation in. This composite shows how the reorganization is structured.
Read more →An Accountant's Guide to CRA Audit Escalation
A practical playbook for the moment a routine CRA audit turns adversarial — recognizing the shift, controlling the paper trail, protecting deadlines, and bringing in co-counsel without losing your client relationship.
Read more →Tax Litigation vs Tax Planning: Which Do You Need?
Tax litigation and tax planning solve opposite problems at opposite ends of the timeline — one fights a position the CRA has taken, the other builds a position before the CRA looks. This guide defines each, shows when you need which, and explains how the two connect.
Read more →Deferring Tax the Smart Way: Rollovers, the Capital Gains Reserve, and the Estate Freeze
A dollar of tax paid years from now costs less than a dollar paid today. Tax-free rollovers, the capital gains reserve, and the estate freeze are three tools Canadians use to defer tax and shift growth to the next generation.
Read more →Tax Planning at Death in Canada: Deemed Disposition, the PRE & the Spousal Rollover
Canada has no inheritance tax, but the deemed disposition on death taxes accrued capital gains as if you sold everything the moment before you died. The spousal rollover, the principal residence exemption, and post-mortem planning are how estates manage that bill.
Read more →Post-Mortem Tax Planning and Pipeline Strategies for Pharmacist Estates
When a pharmacist dies owning corporation shares, the same value can be taxed twice. Pipeline planning and the subsection 164(6) loss carry-back are the two principal answers — and the will has to grant the executor authority to use them.
Read more →CRA Voluntary Disclosure Program: Eligibility, Step by Step
The CRA Voluntary Disclosures Program lets you correct unreported income, unfiled returns, and missed forms before CRA finds you. Here are the five eligibility tests, the General vs Limited tracks, and what relief is available.
Read more →How to File a Notice of Objection (Step by Step)
A notice of objection is the formal way to dispute a CRA reassessment. This step-by-step guide covers the 90-day deadline, the one-year extension, Form T400A, what to include, and what happens once Appeals takes over.
Read more →Audit Defence vs Voluntary Disclosure vs Objection & Appeal: Choosing Your CRA Route
Audit defence, the Voluntary Disclosures Program, and the objection-and-appeal route solve different CRA problems at different stages. This decision guide explains which route fits which situation, the timing, and what each can and cannot achieve.
Read more →Family Trusts in Canadian Tax & Estate Planning
A discretionary family trust can split income, multiply the capital gains exemption, and hold growth shares outside an owner's estate — within the limits set by TOSI, the attribution rules, and the 21-year rule. Here is how they work.
Read more →Gross Negligence Penalties (s.163(2)): How They're Applied and How They're Challenged
A gross-negligence penalty under s.163(2) adds 50% of the understated tax. The CRA carries the burden of proof, the Venne standard is demanding, and these penalties are challenged more successfully than most taxpayers assume.
Read more →CRA Audit Readiness Checklist
A practical checklist for Canadians and businesses facing a CRA audit: documents to gather, what to do and avoid, the deadlines that matter, and when to involve a tax lawyer.
Read more →NFTs, Staking, Mining & DeFi: Canadian Tax Treatment
Mining, staking rewards, DeFi yield, and NFTs each raise distinct Canadian tax questions — business versus hobby, income on receipt, and the difference between creating and trading. This guide explains how the CRA approaches each.
Read more →GST/HST Audits: Common Triggers and How to Defend Them
GST/HST audits look like accounting reviews, but most reassessments turn on legal-characterization questions. This guide covers the common triggers, the audit process, documentation, typical adjustments, and the objection route.
Read more →Common Tax Mistakes New Businesses Make — and How to Avoid Them
Most new-business tax trouble comes from a short list of avoidable mistakes: misjudging employee-versus-contractor status, ignoring the HST threshold, spending trust money, and estimating the deductions auditors love to deny. Here is the list.
Read more →UAE Holding Companies and Treaty Planning: Substance, the Principal Purpose Test, and the Canada–UAE Treaty
The UAE's 140-plus treaty network and free zone infrastructure make it a natural cross-border holding location — but only for companies with real substance. Paper structures no longer survive the Principal Purpose Test or foreign scrutiny. Here is how to build one that holds up.
Read more →Dealing With a CRA Collections Officer: What to Say, What Not to Say, and Your Rights
A call from a CRA collections officer can be unnerving. Knowing what the officer can and cannot do, what you are obliged to disclose, and when to bring in representation keeps a difficult conversation from making things worse.
Read more →What Triggers a CRA Audit
Most CRA audits are not random. This guide explains the common red flags, the industries that draw extra scrutiny, the difference between random and targeted selection, and practical steps that reduce audit risk without changing how you live or run your business.
Read more →Pipeline Planning (s.84.1) to Avoid Double Tax After Death
When a shareholder dies owning private-company shares, the same value can be taxed twice — once on death, again when the corporation is wound up. A post-mortem pipeline extracts the surplus as capital instead. Here is how it works and where section 84.1 bites.
Read more →U.S. Citizens Living in Canada: Your Annual U.S. Filing Obligations
The United States taxes its citizens wherever they live. If you are an American or dual citizen in Canada, here are the U.S. returns and disclosures you owe each year, the Canadian accounts that cause the most trouble, and the way back if you are behind.
Read more →The Gross Negligence Penalty: Reverse Onus and the Report You Should Always Demand
The gross negligence penalty under subsection 163(2) is the harshest the CRA can assess — 50% of the understated tax. Because the burden is reversed, it is also one of the most defensible. Here is how it works and the one document you should always request.
Read more →Back Taxes and Taxes Owing: Your Options When You Can't Pay
Owing the CRA more than you can pay is a common and resolvable situation. This guide explains your options — payment arrangements, taxpayer relief, and the Voluntary Disclosure Program — and when penalties and interest can actually be reduced or cancelled.
Read more →The Tax Court of Canada Appeal Process
The Tax Court of Canada hears appeals from CRA reassessments. This guide explains the Informal and General Procedures, the dollar thresholds, the stages from notice of appeal to judgment, evidence, settlement, and costs.
Read more →When Do You Need a Tax Lawyer vs. an Accountant? A Decision Guide
Tax lawyers and accountants do different jobs, and the strongest results usually come from using both. This decision guide maps common situations to the right professional — and explains privilege, the one thing only a lawyer brings.
Read more →Offshore Assets & T1135: Coming Clean Through the VDP
Foreign accounts, foreign property, and foreign entities carry Canadian reporting duties — T1135, T1134, and more — backed by steep penalties. The VDP is the path to fix years of missed foreign reporting before CRA finds it.
Read more →Director's Liability for Unremitted Source Deductions & GST/HST (s.227.1)
When a corporation fails to remit source deductions or GST/HST, the CRA can assess directors personally under s.227.1 (and s.323 ETA). Two defences matter most: the two-year limitation period and the due-diligence defence.
Read more →Case Study: Defending a Director Against a Section 227.1 Liability Assessment
An illustrative director's-liability scenario: the CRA assessed a director personally for a corporation's unremitted source deductions and GST/HST. This composite shows the due-diligence and procedural defences available under section 227.1.
Read more →Settling a Tax Court Appeal Before Trial
Most Tax Court appeals settle before trial — but only on a principled basis. This guide explains the role of Department of Justice counsel, the Galway and CIBC principle, minutes of settlement, and when settlement is and is not possible.
Read more →How to Present Evidence and Witnesses at the Tax Court (Self-Rep Guide)
A practical guide for self-represented taxpayers on getting documents into evidence, preparing and calling witnesses, the basics of examination and cross-examination, and testifying credibly yourself.
Read more →Questions to Ask Before Hiring a Canadian Tax Lawyer
A practical buyer's checklist for choosing a Canadian tax lawyer: solicitor-client privilege, fixed fees, the free consultation, experience with your specific issue, and who actually does the work. Use it with any firm you consider.
Read more →CRA Collections: Frozen Accounts, Requirements to Pay, and Garnishments
The CRA can freeze accounts, issue requirements to pay, and garnish wages — often without a court order. This guide explains those powers, whether the CRA can collect while you object, taxpayer relief, and payment arrangements.
Read more →Voluntary Disclosure vs Waiting for a CRA Audit
Coming forward through the VDP before CRA contacts you can take prosecution and the heaviest penalties off the table. Wait for an audit and the door closes. Here is the risk comparison, side by side.
Read more →Section 160: Derivative Tax Liability for Non-Arm's-Length Transfers
Section 160 makes someone who receives property from a tax debtor for less than fair market value jointly liable for the debtor's tax — capped at the value transferred. There are four conditions, and real defences.
Read more →Questions to Ask Before Hiring CRA Audit Representation
Choosing who represents you in a CRA audit is a consequential decision. This checklist of questions covers lawyer versus accountant, solicitor-client privilege, fixed fees, who actually handles your file, and how quickly you can expect a response.
Read more →Sections 85, 86 & 51: The Rollover Provisions Compared
Sections 85, 86, and 51 of the Income Tax Act all let assets or shares move on a tax-deferred basis, but each does a different job. Here is what each provision does, when to use it, and how they compare side by side.
Read more →After the Tax Court: Appealing to the Federal Court of Appeal
A Tax Court loss is not the end of the road. An appeal lies to the Federal Court of Appeal — but it is governed by a deadline of thirty days, a different standard of review, and a far narrower scope than the trial itself.
Read more →Notice of Objection vs Tax Court Appeal: Which Path and When
Objection and Tax Court appeal are two different stages in disputing a CRA reassessment, and the order matters. Here is the sequence, the timelines, and the 90-day no-decision rule that lets you skip ahead to court.
Read more →Boutique Tax Law Firm vs General-Practice Firm: What the Difference Means for Your CRA File
When the CRA is involved, the type of firm you choose changes how your file is handled. This neutral comparison looks at tax focus, who actually does the work, fee models, and response time — so you can match the firm to the matter.
Read more →The Executor's Role, Probate & Probate Fees Across Canada
The executor turns a will into reality — collecting assets, paying debts and taxes, and distributing what is left. Probate validates the will and the executor's authority, and probate fees vary widely by province. Here is the role, the process, and the personal liability.
Read more →LCGE & QSBC Purification: Multiplying the Capital Gains Exemption
The Lifetime Capital Gains Exemption shelters over a million dollars of gain on qualifying small-business shares — and can be multiplied across a family. But the three QSBC tests reach back 24 months, so the planning window is earlier than most owners think.
Read more →Tax Evasion vs Tax Avoidance: Where the Line Is
Tax avoidance is legal; tax evasion is a crime. Between them sits the GAAR, which can reverse a transaction's tax result without making it criminal. Knowing which side of the line you are on shapes everything that follows.
Read more →Voluntary Disclosure Readiness Checklist
Thinking about coming forward to the CRA? Work through this checklist: the five eligibility tests, the documents to assemble, and the timing that matters — ideally before any CRA contact.
Read more →Family Trusts for Pharmacists: Multiplying the Lifetime Capital Gains Exemption
A family trust can let a pharmacist's spouse and children each claim their own Lifetime Capital Gains Exemption on a sale — sheltering several million dollars — while voting control stays in licensed hands. Here is how the structure works, and its limits.
Read more →Evidence and Burden of Proof in Tax Court
In a Tax Court appeal the burden is largely on the taxpayer: the Minister's assumptions of fact are presumed correct, and your job is to demolish them. This guide explains the onus, documentary versus viva voce evidence, and why credibility decides cases.
Read more →Estate Freeze: Locking In Today's Value, Transferring Tomorrow's Growth
An estate freeze caps your business's value at today's price in your hands and shifts future appreciation to the next generation. Here's how the mechanics work and when they pay off.
Read more →Case Study: Appealing a Confirmed Reassessment to the Tax Court of Canada
An illustrative Tax Court scenario: after a notice of objection was denied, a taxpayer appealed to the Tax Court of Canada. This composite shows how an appeal is pleaded, how discovery is used, and how most appeals resolve.
Read more →How to Save Money in a CRA Audit: Risk Factors and a Calm Plan
An audit can cost thousands if it goes badly — but much of the outcome is in your control. Learn the risk factors that attract audits and the practical steps that keep one from spiralling.
Read more →Lose Twice, Win Once: Why CRA Cases Are Often Won in Tax Court
Inside the four walls of the CRA, an auditor can ignore evidence and an appeals officer can confirm a bad assessment. But the Tax Court of Canada applies the rules of evidence — which is why many cases lost at audit and objection are won at court.
Read more →Getting Back Into Tax Compliance: A Step-by-Step Path for Non-Filers
If you have fallen out of the tax system, getting back in follows a clear sequence — gather your records, decide between the Voluntary Disclosure Program and straightforward filing, prepare returns oldest-to-newest, and arrange to deal with any balance owing.
Read more →Leaving Canada: How Departure Tax Catches Your Net Worth
When you cease to be a Canadian tax resident, section 128.1 of the Income Tax Act treats most of your worldwide assets as sold at fair market value the day you leave. Here's the rule and how to plan around it.
Read more →Tax Court Forms and Deadlines: A Checklist for Self-Represented Taxpayers
Everything a self-represented taxpayer needs to file a Tax Court appeal: the Notice of Appeal, the 90-day deadline and how extensions work, filing fees, and a printable step-by-step checklist.
Read more →Net Worth Audits: How the CRA Builds an Indirect-Income Assessment
A net worth audit reconstructs your income from changes in your wealth rather than from your records. This guide explains how the CRA builds an indirect-income assessment, why these files are difficult, and how the reconstruction can be challenged.
Read more →Crypto and the CRA: Audit Risks, Exchange Data Requests, and Record-Keeping
The CRA now receives transaction data directly from Canadian crypto exchanges and uses blockchain-analysis tools. This guide explains crypto audit triggers, unnamed-persons requirements, the records to keep, and voluntary disclosure for unreported crypto.
Read more →Business Records That Survive an Audit: What to Keep, and for How Long
There is no rule in the Income Tax Act that you must keep an original receipt — yet an auditor who asks for one and gets a photocopy can deny the expense outright. Here is how to keep records that hold up when the Canada Revenue Agency comes calling.
Read more →UAE Free Zones and Qualifying Free Zone Person (QFZP) Status: How the 0% Rate Actually Works
A UAE free zone entity can earn a 0% corporate tax rate on qualifying income — but only as a Qualifying Free Zone Person, and only if it meets substance, income, and transfer-pricing conditions every year. One stray mainland sale can cost the benefit for the whole period.
Read more →CRA Liens and Charges on Your Property: How They Arise and How to Deal With Them
When a tax debt goes unpaid, the CRA can register a certificate in the Federal Court and secure a charge against your real property. Here is how a tax lien arises, what it does, and the options for removing it.
Read more →Multiplying the Lifetime Capital Gains Exemption Across Your Family
The LCGE shelters $1,016,836 per individual on the sale of qualifying small-business-corporation shares. A properly-structured family trust can multiply that exemption across multiple beneficiaries.
Read more →Estate Freeze Mechanics: Section 86 vs Section 85 vs Section 51
An estate freeze caps the value of what you own today and shifts future growth to the next generation. The three workhorse techniques — sections 86, 85, and 51 — each freeze in a different way. Here is when each applies.
Read more →Buying U.S. Real Estate as a Canadian: Ownership Structures and Tax
A Florida condo is simple to buy and complicated to own. Here is how the ownership structure you choose drives your income tax on rent, your withholding when you sell, and your estate-tax exposure at death — and how to choose before you sign.
Read more →When Should an Accountant Refer a Client to a Tax Lawyer?
Audit escalation, objection deadlines, gross-negligence-penalty exposure, criminal-tax red flags, and the limits of accountant-client confidentiality. A practical set of triggers for when a CRA file warrants a tax lawyer.
Read more →Denied Input Tax Credits: Why the CRA Disallows ITCs and How to Respond
Most input tax credit denials are documentation denials, not substantive ones. This guide covers the s. 169(4) ETA requirements, supplier registration validity, the common denial reasons, and how to dispute a disallowed ITC.
Read more →Tax Lawyer vs Accountant for a CRA Dispute
For a CRA dispute, the choice between a tax lawyer and an accountant is not either/or. This guide explains what each professional does well, when each is the right call, why solicitor-client privilege matters, and how the two work together under a co-counsel model.
Read more →Section 94: How Canadian Tax Reaches Foreign Trusts
Section 94 of the Income Tax Act can deem a non-resident trust to be a Canadian-resident trust — and make Canadian contributors and beneficiaries jointly liable for its tax — whenever a Canadian touches the structure.
Read more →Costs and Cost Awards at the Tax Court of Canada
Winning a Tax Court appeal can come with a cost award — but how much depends on the tariff, whether the Court grants a lump sum, and, critically, whether a written settlement offer was made under Rule 147 and beaten at trial.
Read more →Handling a CRA Audit Yourself vs. With a Tax Lawyer: An Honest Comparison
Some CRA audits are fine to handle yourself; others put real money and legal exposure at stake. This balanced comparison weighs privilege, scope, risk, and cost — and is candid about when self-representation is the sensible choice.
Read more →Case Study: A Voluntary Disclosure for Unreported Offshore Income and T1135 Filings
An illustrative VDP scenario: a taxpayer with years of unreported offshore income and missed T1135 forms came forward before the CRA made contact. This composite shows how a voluntary disclosure is assessed and prepared.
Read more →Cross-Border Move Tax Checklist (Canada ↔ U.S.)
Moving between Canada and the U.S.? This checklist covers departure tax, account cleanup (TFSA, RESP, PFIC mutual funds), and the filing obligations that attach on both sides of the border.
Read more →Multiplying the Lifetime Capital Gains Exemption
The Lifetime Capital Gains Exemption shelters over a million dollars of gain on qualifying small-business shares — and a family trust can let several family members each claim their own. Here are the QSBC tests, multiplication, and crystallization.
Read more →What to Expect at a Tax Court Hearing
The day of a Tax Court hearing can feel intimidating. This guide walks through where the hearing happens, who is in the room, the order of events, how examination and cross-examination work, and when to expect the judgment.
Read more →Salary vs Dividend: The Owner-Manager Question for 2026
For most Canadian owner-managers, the salary-vs-dividend mix is the largest annual tax decision. Here's the framework, the math, and the changes for 2026.
Read more →Snowbirds and the IRS: How Many Days Is Too Many?
The IRS's substantial-presence test counts your US days on a rolling three-year formula. Cross 183 and you become a US tax resident — unless you file the right form, in the right window, with the right facts.
Read more →Post-Mortem Tax Planning: Avoiding Double Tax on Death
When a Canadian dies owning private corporation shares, the same value can be taxed twice — once on the terminal return and again when the corporation distributes its surplus. Pipeline planning and the subsection 164(6) loss carryback are the two answers.
Read more →The 21-Year Rule and What to Do About It
Every family discretionary trust faces a deemed disposition under ITA s. 104(4) every 21 years. The unwind, the restate, and the rollout — three responses depending on what the family needs.
Read more →The Peril of Family Asset Transfers: Section 160 and the $1 Transaction
People deposit money in each other's accounts, add a parent to title, or sell the cottage to a child for a dollar — and inadvertently create tax problems that can be impossible to fix. This guide explains section 160 and the non-arm's-length rules.
Read more →Vehicle and Home-Office Deductions: Claim Them Without Losing Them
Vehicle and home-office expenses are two of the most audited deductions in Canada — not because they are improper, but because they are so often estimated. A simple log and a measured percentage make them defensible.
Read more →Corporate-Owned Life Insurance and the Purification Strategy for Pharmacists
Held in the right entity, corporate-owned life insurance funds estate taxes, supports buy-sell agreements, and protects QSBC status. Held in the wrong entity, its cash value can taint the pharmacy corporation and cost the LCGE.
Read more →Arbitrary and Notional Assessments: When the CRA Files for You
When you don't file, the CRA can assess you anyway under subsection 152(7) of the Income Tax Act — an arbitrary or notional assessment built from the slips it holds, without your deductions. This guide explains how those assessments work and how to displace them.
Read more →FIRPTA: Why Canadian Sellers of US Real Estate Often Over-Pay at Closing
When a Canadian sells US real estate, the buyer is required to withhold up to 15% of the gross sale price under FIRPTA — far more than the actual tax in most cases. Form 8288-B reduces the hold-back if filed early.
Read more →Case Study: Challenging a Section 163(2) Gross-Negligence Penalty
An illustrative scenario: the CRA proposed a 50% gross-negligence penalty under section 163(2) on top of a reassessment. This composite shows how the penalty was contested as a separate ground and ultimately withdrawn.
Read more →Powers of Attorney in Canada: Property, Personal Care & Incapacity
A will takes effect when you die; a power of attorney takes effect while you are alive but unable to act. Here is how financial and personal-care POAs work, what an enduring POA adds, and the pitfalls that make a POA fail when it is needed most.
Read more →Common Mistakes Self-Represented Taxpayers Make at the Tax Court (and How to Avoid Them)
The recurring pitfalls that sink self-represented Tax Court appeals — missed deadlines, the wrong procedure, arguing facts as if they were law, and showing up with no evidence — and how to sidestep each one.
Read more →Estate Planning & Freeze Checklist for Business Owners
Planning an estate freeze for your private company? This checklist covers valuation, share structure, the family trust, the documents to put in place, and the ongoing items that keep the structure sound.
Read more →When Your Business Actually Needs a Holdco
Holding companies are sometimes pitched as a one-size-fits-all answer for Canadian business owners. They're not — but when they're the right structure, they're the right structure for serious reasons.
Read more →Registering for GST/HST and Payroll: The Trust-Tax Obligations That Reach You Personally
GST/HST you collect and source deductions you withhold are not your money — you hold them in trust for the Canada Revenue Agency. Mishandle them and the corporate shield will not save you. Here is how registration and remittance actually work.
Read more →Streamlined Filing Procedures: A Path Back to US Compliance
The IRS's Streamlined Foreign Offshore Procedures provide a structured, penalty-free path for US persons abroad who haven't been filing. Three years of returns, six years of FBARs, one signed certification — and the file is closed.
Read more →Comparing Canadian Tax Law Firms: A Practical Framework
A neutral, criteria-based way to compare Canadian tax law firms: tax-exclusivity, who handles the file, fee model, response time, dispute vs planning depth, cross-border reach, and privilege. Apply it to any firm you consider — including this one.
Read more →Appealing a Net-Worth Assessment at the Tax Court
Net-worth assessments estimate income from the growth in a person's assets. At the Tax Court, the appeal is fought on the methodology — opening balances, non-taxable sources, and the unproven assumptions baked into the CRA's calculation.
Read more →Section 85 Rollovers: How Tax-Deferred Restructuring Works
Section 85 of the Income Tax Act lets you transfer property to a Canadian corporation at any agreed amount between cost and FMV — the backbone of estate freezes, incorporations, and most corporate reorganizations.
Read more →UAE Tax Residency for Individuals: Day Tests, the TRC, and What Relocating Canadians Should Know
The UAE has no personal income tax, but it does have domestic tax-residency tests and issues Tax Residency Certificates for treaty purposes. For Canadians moving to the Emirates, becoming a UAE resident is only half the story — severing Canadian residency is the other half.
Read more →Taxpayer Relief: Cancelling CRA Interest and Penalties (Form RC4288)
The CRA has discretion to cancel or waive interest and penalties where circumstances justify it — CRA delay, financial hardship, or extraordinary events. There is a ten-year limit, and the request is made on Form RC4288.
Read more →Case Study: Challenging a CRA Net-Worth (Indirect Income) Assessment
An illustrative net-worth assessment scenario: the CRA reconstructed a taxpayer's income from lifestyle and assets and reassessed years of alleged unreported income. This composite shows how an indirect assessment is rebuilt and challenged.
Read more →Section 85 Rollover: Tax-Deferred Transfers to a Corporation
Section 85 of the Income Tax Act lets you move appreciated property into a corporation without triggering an immediate capital gain. Here is how the elected amount, boot, share consideration, and the T2057 election all fit together.
Read more →Canadian Snowbirds and U.S. Tax: Substantial Presence, Form 8840, and Treaty Ties
Spend enough winters in Florida and the IRS can treat you as a U.S. tax resident. Here is how the substantial-presence test works, how Form 8840 and the treaty keep you Canadian, and the estate-tax trap that survives even when you win.
Read more →The Co-Counsel Model: How Accountants Work With Barrett Tax Law
Barrett Tax Law works alongside Canadian accountants as co-counsel — not as a competitor. Your client stays your client. Here is how the referral structure works, who does what, and how privilege attaches once a lawyer is engaged.
Read more →US Estate Tax for Canadians: Who's Exposed and Why
Canadians who own US-situs assets — Florida condos, US-corporation shares, tangible US property — are exposed to US estate tax at death. The treaty's prorated unified credit helps, but doesn't eliminate the risk for larger estates.
Read more →Succession Planning for Business Owners
Every business owner exits eventually — by transition to family, a sale to a third party, or by default on death. Planning the exit years ahead turns a tax problem into a tax plan. Here are the options, the structures, and the timing.
Read more →Corporate Year-End Tax Checklist
A year-end checklist for incorporated business owners: the salary-vs-dividend remuneration mix, capital dividend account planning, instalments, and the filing deadlines that follow your fiscal year-end.
Read more →Cryptocurrency Tax in Canada: Capital Gains vs Business Income, Reporting, and the CRA
Canada taxes cryptocurrency as property, not currency. Whether your gains are capital gains or business income, every disposition is taxable, and how you track adjusted cost base and report it determines what you owe.
Read more →How to File a Notice of Appeal to the Tax Court of Canada
After the CRA confirms a reassessment, you have 90 days to appeal to the Tax Court of Canada. This step-by-step guide covers the deadline, extensions, choosing a procedure, filing methods, what goes in the notice of appeal, and the Crown's reply.
Read more →TOSI: How the Tax on Split Income Rules Apply to Your Family
Section 120.4 of the Income Tax Act applies top marginal rates to most family-member dividends from a related business. The exceptions matter — here's how to use them.
Read more →GST/HST New Housing & Rental Rebate Disputes
The CRA reviews and claws back new housing and rental rebates more than almost any other GST/HST item. This guide covers eligibility, the primary-place-of-residence test, common denials, assignment sales, and the objection route.
Read more →Preparing Your Own Tax Court Case: Documents, Chronology, and Issues
How a self-represented taxpayer builds a Tax Court case: organizing your documents, writing a chronology, pinning down the real issues, and giving the judge exactly what is needed to rule your way.
Read more →Cross-Border Estate Planning When One Spouse is American
A US citizen who leaves property to a non-US-citizen spouse loses the unlimited marital deduction. The QDOT defers the estate tax, but at the cost of trustee complexity. The right structure depends on where the survivor will live.
Read more →Case Study: Defending a CRA Audit That Alleged Unreported Income and Disallowed Expenses
An illustrative CRA audit scenario: a small-business owner faced a reassessment for unreported income and disallowed expenses. This composite walks through how an audit defence is built and how the proposed adjustments were challenged.
Read more →Inside CRA Collections: The Officer, the Powers, and How to Negotiate
CRA collections officers behave nothing like private-sector collectors — they are rewarded for closing files, not collecting money. This guide explains the collector's incentives, the powers they wield, and how a payment plan actually gets made.
Read more →Owner-Manager Tax Savings: Corporations, Family Wages, and Income Splitting
Owner-managers have planning tools employees do not: a corporation that defers tax, reasonable wages to family, and partnership structures. Here is how each works — and the TOSI and attribution traps to respect.
Read more →Testamentary Trusts, Henson Trusts & Blended-Family Planning
A plain will divides property; a will with the right trusts protects it. Discretionary trusts, Henson trusts, life estates, and mutual wills let you provide for a second spouse, a disabled child, or young beneficiaries without unintended consequences.
Read more →Selling Your Pharmacy: Maximizing Value and Minimizing Tax
Selling a pharmacy is both a business transaction and a life milestone. Purification, a share-vs-asset decision, family-trust multiplication of the LCGE, and a going-concern HST election can change the after-tax result by hundreds of thousands of dollars.
Read more →What Happens If You Don't File Your Taxes in Canada
Not filing a Canadian tax return sets off a predictable chain of consequences: late-filing penalties, daily compounding interest, arbitrary assessments, collections enforcement, and — in serious cases — prosecution. Here is what each stage actually looks like.
Read more →Tax Planning for High-Net-Worth Families
Trusts, estate freezes, philanthropy, cross-border exposure, and asset protection — the planning building blocks for families with substantial wealth, and how they interact over a generation.
Read more →Family Trusts in Canadian Estate Planning
A discretionary family trust can split income, multiply the capital gains exemption, and hold growth shares for the next generation — provided the attribution rules and the trust's design are handled with care. Here is how they work.
Read more →Post-Mortem Tax Planning: Pipeline, Bump, and Loss Carryback
When a Canadian shareholder dies owning private-company shares, the estate has 36 months to deploy three coordinated tax strategies. Skipping them costs heirs hundreds of thousands.
Read more →Incorporating Your Business: What Changes, and Why It Matters
Incorporation turns your business into a separate legal person — with its own tax return, its own liability shield, and its own planning opportunities. Here is what actually changes when you incorporate, and the pitfalls to avoid.
Read more →Appealing Gross Negligence Penalties at the Tax Court
The gross negligence penalty under section 163(2) is one of the few assessments where the onus shifts to the Minister. At the Tax Court, that reversal of burden is the centre of the case — and the reason these penalties so often fall.
Read more →RRSP Withdrawals for US Residents: How the Treaty Mechanics Work
An RRSP earned while you lived in Canada is sheltered from US tax during accumulation under Article XVIII of the Canada-US treaty. Withdrawals are US-taxable in the year received, with foreign tax credit relief for the Canadian withholding.
Read more →The Tax Court General Procedure, Explained
The General Procedure is the Tax Court's full-litigation track: formal pleadings, documentary discovery, oral examinations, undertakings, expert evidence, and a trial under the rules of evidence. Here is how each stage works and when it applies.
Read more →Pre-Immigration to Canada: Resetting Your Tax Cost Base
When you become a Canadian tax resident, paragraph 128.1(1)(b) of the Income Tax Act gives you a fair-market-value cost base reset on most of your worldwide assets. Pre-immigration planning ensures the reset captures the right gains.
Read more →UAE Corporate Tax Explained: What Canadians and Cross-Border Businesses Need to Know
The UAE introduced a 9% corporate tax for financial years starting on or after 1 June 2023. Here is how the regime works — scope, the AED 375,000 threshold, residency by management and control, free zone treatment, and what it means for Canadian-owned entities.
Read more →CRA Payment Arrangements: How to Negotiate a Plan You Can Live With
When you cannot pay a tax debt in full, a payment arrangement spreads it over time. The CRA expects financial disclosure, will push for the shortest term, and can say no — here is how the process actually works.
Read more →Beware the Net Worth Audit: Five Pitfalls of the CRA's Lifestyle Method
The net worth method is the fastest and crudest way the CRA can audit a taxpayer — and it produces large, unfair reassessments. Here are the five pitfalls Dale Barrett sees in nearly every net worth file, and how to push back.
Read more →A Canadian Business Owner's Guide to Deducting Expenses the Right Way
Most of the tax a small business owner saves comes from claiming the right expenses and being able to prove them. Here is how business deductions work, what you can claim, and how to keep claims audit-ready.
Read more →Years of Unfiled Tax Returns in Canada: What to Do Now
Several years of unfiled Canadian tax returns is a fixable problem — but the way you fix it matters. This guide covers the risks of waiting, how to bring the returns current, and when the Voluntary Disclosure Program is the right path versus simply filing.
Read more →Becoming a US Resident: Year-One Planning for Canadians
The Canadian who moves to the US triggers Canadian departure tax in the year of move AND a US tax-residency transition mid-year. The dual-status return, the Form T1244 election, and the PFIC clean-up all need to happen in the same calendar year.
Read more →The Estate Freeze: Locking In Today's Value for Tomorrow's Tax
An estate freeze fixes the value of a business owner's interest at today's number, so future growth — and the tax on it — accrues to the next generation instead of the estate. Here is what a freeze does and how it is built.
Read more →What Makes a Will Valid in Canada
A will only does its job if it is legally valid. Age, capacity, free choice, signing, and impartial witnesses are the building blocks — and the rules vary by province. Here is what each requirement means and where wills most often go wrong.
Read more →Pharmacy Succession Planning: Corporate Reorganizations That Preserve Value
Every pharmacist eventually retires, sells, or transfers the practice. A succession plan built on section 85 rollovers, purification, an estate freeze, and a Holdco preserves QSBC status and the Lifetime Capital Gains Exemption.
Read more →Choosing a Business Structure: Sole Proprietorship, Partnership, or Corporation
Before you invoice your first client, you have to decide what your business is in the eyes of the law. The choice among a sole proprietorship, a partnership, and a corporation shapes your tax bill, your liability, and your exit for years.
Read more →The Tax Court Informal Procedure, Explained
The Informal Procedure is the Tax Court's faster, cheaper track for smaller disputes — generally $25,000 or less in federal tax per year, or $12,000 in disputed GST/HST. Here is how it works, the simplified rules, and when to choose it.
Read more →How to Represent Yourself at the Tax Court of Canada (Informal Procedure)
A start-to-finish guide for self-represented taxpayers using the Tax Court's Informal Procedure: filing your appeal, the timeline, getting ready, and what happens on hearing day.
Read more →GST/HST Appeals at the Tax Court of Canada
Denied input tax credits, a clawed-back new-housing rebate, or a backdated registration assessment can all be appealed to the Tax Court. The procedure differs from an income-tax appeal in ways that matter for timing, collections, and onus.
Read more →Tax Planning for Business Owners: A Practical Guide
Remuneration mix, income splitting and TOSI, holding companies, the lifetime capital gains exemption, RDTOH and CDA, and year-end planning — the moving parts of a business owner's tax plan, explained in plain language.
Read more →Support Payments as Deductible Expenses and Taxable Income
By Martina Caunedo This memorandum is intended to provide information regarding the deductibility of support payments as expenses for the payor and their taxation as income for the recipient. Support payments are deductible expenses for the payor and taxable income for …
Read more →Victim Surcharge – Section 737 of the Criminal Code
Victim Surcharge – Section 737 of the Criminal Code By Matthew Rochester Introduction This memo seeks to identify how a defendant can successfully apply for exemption to the imposition of a victim surcharge under section 737 of the Criminal Code. Exceptions under statut…
Read more →Intercompany Loans: Mitigating Tax Risks under Canadian Law
Intercompany Loans: Mitigating Tax Risks under Canadian Law By Dale Barrett Navigating the business landscape is no easy task, particularly when it comes to intercompany loans between corporations with a common owner. If you are a business owner who owns multiple compan…
Read more →Maximizing The Small Business Deduction: Preventing Corporations from Being Associated
Maximizing The Small Business Deduction: Preventing Corporations from Being Associated Barrett Tax Law The Small Business Deduction. The government giveth a wondrous gift, but if you're not careful, they taketh back. In Ontario, there are preferential tax rates that app…
Read more →Directors’ Liability and Section 160 Assessments
Directors can be held liable for a corporation’s debt Under Canadian tax law, directors of a corporation can be held personally liable for certain components of a corporation’s tax debt which the corporation cannot pay, such as in the case of an insolvency. Generally sp…
Read more →Tax Guidance with Respect to Real Estate Property for Canadian Non-Residents
When a non-resident of Canada earns income from a rental property or disposes of a real property in Canada, the tenant or purchaser may be required to withhold certain amount of tax which is usually 25% and remit that to the Canada Revenue Agency (CRA). This article wil…
Read more →Section 116: A Purchaser's Liability in a Real Estate Transaction When Buying from a Potential Non-resident
A non-resident is generally taxable in Canada on the disposition of Canadian real estate. It is more difficult for the Canada Revenue Agency (CRA) to collect tax from a non-resident, so there are additional provisions to ensure the tax is pre-paid to protect against the…
Read more →Conditions of a Valid Voluntary Disclosure Program Application
What is the Voluntary Disclosure Program In recent years, the CRA has taken a rather aggressive approach in recovering uncollected taxes. The Offshore Tax Informant Program awards informants 5 to 15 percent of the federal tax collected if their leads result in more than…
Read more →Voluntary Disclosure Program – Guidance from a Canadian Tax Lawyer
What is the Voluntary Disclosure Program Taxpayers in Canada are supposed to file their tax returns accurately and timely, otherwise there may be interest and penalties or even criminal prosecutions depending on the situation. If a taxpayer fails to do so, he is not ent…
Read more →Section 216 election – guidance from Canadian tax lawyers on rental income and non-resident tax.
Section 216 election – guidance from Canadian tax lawyers on rental income and non-resident tax. When non-residents receive rental income from rental or immovable property in Canada, the tenant or agent must withhold non-resident tax which is 25% on the gross rental inc…
Read more →Tax Residence Determination in Canada – guidance from Canadian tax lawyers
The basis for Canadian taxation The Canadian income tax system is based on residence status. Under subsection 2(1) of the Income Tax Act , an income tax is payable on the taxable income of every person resident in Canada at any time in the year. There is a common misund…
Read more →Canada Revenue Agency Focussing on Staffing (Employment) Agency Audits – Guidance from Canadian Tax Lawyers
Canada Revenue Agency is shifting attention to Staffing Agencies Recently the Canada Revenue has been ramping up their audits of Employment Agencies, an industry which is estimated to have defrauded the CRA of hundreds of millions of dollars of HST. The problem (for the…
Read more →How to Deal with Tax Search Warrants – Guidance from Canadian Tax Lawyers
The CRA cannot use its civil audit powers in a criminal investigation When the Canada Revenue Agency (CRA) investigates potential tax fraud, they will typically rely on search warrants in order to seize books and records to gather evidence. This is because when the CRA …
Read more →Specified Foreign Property - Guidance from Canadian Tax Lawyers
Foreign property reporting requirements in Canada – A Canadian tax lawyer’s guidance on T1135 obligations When a Canadian resident holds specified foreign properties with a cost exceeding $100,000 anytime during the taxation year, he or she must file the T1135 form – Fo…
Read more →The “Unnamed Persons” Search: An Enhanced Ability For The CRA To Identify Taxpayers To Audit.
By Alex Kerslake Taxpayers are often aware of the common triggers for a Canada Revenue Agency (CRA) audit, such as claiming large expenses, failing to report a tax slip, or simply working in an industry known to underreport their income. There are many other methods the…
Read more →Deducting life insurance costs: Why opportunity may be overlooked (Originally on The Lawyer’s Daily)
By Dale Barrett and Simon Townsend (January 26, 2021, 12:42 PM EST) -- In part one, we discussed paragraph 20(1)(e.2) in the Income Tax Act (the Act), which allows an individual or business to deduct the reasonable cost of life insurance in the event it is used as colla…
Read more →Social media influencers and game streamers: Beware of CRA (Originally on The Lawyer’s Daily)
Social media influencers and game streamers can earn hundreds of thousands of dollars per year and are paid in both cash and merchandise. What many of them don’t realize is that the $3,000 free trip to Hawaii that they received as promotional consideration may end up co…
Read more →Deducting life insurance costs: Paragraph 20(1)(e.2) of Income Tax Act explained (Originally on The Lawyer's Daily)
By Dale Barrett and Simon Townsend (January 18, 2021, 3:21 PM EST) -- The cost of life insurance is a cost which is usually borne by individuals and is not something that people think of as a deductible expense. With numerous deductions for loss from a business (or prop…
Read more →Year End RESP Considerations
While many Canadians are aware that the government provides annual grants on contribution to RESPs, many people are simply unaware of the small but important nuances in maximizing those grants. The Canada Education Savings Grant (“CESG”) is currently limited to 20% of t…
Read more →COVID-19 — Updates on Employment Expenses
To Whom It May Concern: On September 11, 2020 the Canada Revenue Agency (“ CRA ”) conducted a consultation hosted by the Canadian Chamber of Commerce. At this consultation, the CRA provided guidance on the deductibility of home office expenses as a result of the COVID-1…
Read more →COVID 19 - New Deductions From Income Sources
The following are considerations on deductions that independent contractors and salaried employees may count against their income due to the current COVID-19 pandemic. If salaried employees are required by contract (written or implied) to maintain a home office, they fu…
Read more →So You’re Working From Home – Deduct your Expenses and Pay Less Tax
Almost all of us have been working from home during the Covid-19 pandemic and many of us will continue to work from home for some time to come. Google just announced that it is going to have its employees to work from home for at least the next year, and personally I ha…
Read more →Estate Freezes: A Silver Lining of COVID-19 (Originally On The Lawyer’s Daily)
With the world in flux and an unprecedented shutdown of the world’s economy, those who were planning to transfer businesses to the next generation have been given what is (hopefully) a once-in-a-lifetime opportunity to defer additional taxes for many years. As valuation…
Read more →Wondering about Canada's 75% Emergency Wage Subsidy?
Here is what we know so far about Canada's Emergency Wage Subsidy, a government program helping businesses avoid having to lay-off their employees during the Covid-19 Pandemic. We will be updating this article as new details are released. The Canada Emergency Wage Subsi…
Read more →A Sad Story about Mr. X. from Country Y (Originally on The Lawyer's Daily)
Meet Mr. X. Don’t judge him by his country of residence. It is not his fault. It wouldn’t be fair. He was taken there as a child by his parents who were fleeing another country for a better life. They could never have predicted how the government of Mr. X’s adopted coun…
Read more →I Lost My Battle with the CRA, but I Won the War (originally on The Lawyer’s Daily)
My law firm cannot make the claim that we have won all of our cases in the Tax Court of Canada, but what we can tell you is that every single case we have won in tax court — either in trial or a settlement — was lost at the CRA objection stage. And in many cases, beside…
Read more →A Tale of Two Taxpayers: The Fiscal Arbitrators Client (originally on The Lawyer’s Daily)
In part one of this series , I considered the situation of a hypothetical wealthy client who was involved in the KPMG tax scheme promoted by a big accounting firm. In the end, the taxpayer signed a settlement with the CRA. Part two relates the story of a typical client …
Read more →20 Tax Audit Triggers
Sometimes a taxpayer is randomly selected for an audit. It’s like winning the worst lottery in the world, and there’s nothing you can do to change that. But apart from a random tax audit, the odds of being targeted for an audit are dependent on a variety of risk factors…
Read more →A Tale of Two Taxpayers: the Wealthy Client (originally on The Lawyer's Daily)
By Dale Barrett – Managing Partner at Barrett Tax Law, Founder of Lawyers & Lattes Legal Cafe , Author of Tax Survival for Canadians: Stand up to the CRA , Editor of the Family Law and Tax Handbook, and Tax Columnist at the Lawyer’s Daily. Originally published by Th…
Read more →The Peril of Family Asset Transfers (originally on The Lawyer’s Daily)
By Dale Barrett – Managing Partner at Barrett Tax Law, Founder of Lawyers & Lattes Legal Cafe , Author of Tax Survival for Canadians: Stand up to the CRA , Editor of the Family Law and Tax Handbook, and Tax Columnist at the Lawyer’s Daily. Originally published by Th…
Read more →Dale Barrett Answers Your Pressing Tax Questions (originally on Global News)
As seen on GlobalNews.ca, Dale Barrett, Managing Partner at Barrett Tax Law, answers your pressing tax questions: THE QUESTION: I don’t understand the implications of adding my adult child as a joint tenant on my home. I know that there can be capital gains tax implicat…
Read more →More Reasons to Abandon the HST (originally on Lawyer's Daily)
By Dale Barrett – Managing Lawyer at Barrett Tax Law and Tax Columnist at the Lawyer’s Daily. Originally published by the Lawyer’s Daily . In my first article in this series, I expressed the opinion that the entire Harmonized Sales Tax system and its legal framework are…
Read more →HST Hurts Economy and Should be Abandoned (originally on Lawyer's Daily)
By Dale Barrett – Managing Lawyer at Barrett Tax Law and Tax Columnist at the Lawyer’s Daily. Originally published by the Lawyer’s Daily . According to the 2008 federal budget, the Harmonized Sales Tax (HST) was claimed by the federal government to be “the single most i…
Read more →CRA Auditors Less Concerned with Correctness than with the Size of Reassessments (originally on Lawyer's Daily)
By Dale Barrett - Managing Lawyer at Barrett Tax Law and Tax Columnist at the Lawyer's Daily. Originally published by the Lawyer's Daily . In any self-reporting or honour system like we have in Canadian taxation, there must be a means by which the state can verify the c…
Read more →Ombudsman Not Protecting Rights of Taxpayers (originally on Lawyer's Daily)
Dale Barrett - Managing Partner of Barrett Tax Law This article was originally published by The Lawyer’s Daily , part of LexisNexis Canada Inc. Although not an actual law as it is in the United States, the Taxpayer “Bill of Rights” sets out sixteen rights, eight of whic…
Read more →Beware The Net Worth Audit
Beware The Net Worth Audit (re-published from TheGaap.net) August 1, 2018 Dale Barrett Managing Partner Barrett Tax Law Arguably, the cheapest, fastest, and dirtiest way in which the CRA can audit a taxpayer is by employing the “net worth” method. It throws all principa…
Read more →Taxation of a Partnership - The Basics
June 18, 2018 By Vivian Esper Tax Lawyer Barrett Tax Law 1-866-278-8424 416-907-8429 TAXATION OF A PARTNERSHIP - THE BASICS The Canadian common law of all provinces defines a partnership as the relation that subsists between or amongst persons carrying on a business in …
Read more →AON Inc. - Current vs. Capital Expenditures
On September 6, 2017, the Tax Court released its decision of AON Inc. v. Canada 2015-1043 (IT) G ruling on the issue of classification of expenditures (current vs. capital). The Honourable Justice Gaston Jorre confirmed the established legal test used to determine the n…
Read more →Late Filing Penalties for RRSP Over-Contribution Canceled by Tax Court
On August 31, 2017, the Tax Court of Canada released a judgment Chiang v. The Queen (2016-2715(IT)I where Sommerfeldt J. canceled late filing penalties under section 204.3 and section 162(1) of the ITA.In brief, the appellant, Mr. Chaing, over-contributed to his RRSPs d…
Read more →Cryptocurrency Profits in Canada: Capital Gains vs. Business Income
March 12, 2018 By Dale Barrett Managing Partner Barrett Tax Law 1-866-278-8424 416-907-8429 Cryptocurrency Profits in Canada: Capital Gains vs. Business Income I am asked all the time whether somebody has to pay capital gains tax on their cryptocurrency gains or whether…
Read more →Tax Treatment of Cryptocurrency Theft and Loss
January 13, 2018 By Dale Barrett Managing Partner Barrett Tax Law 1-866-278-8424 416-907-8429 So, after investing in Bitcoin and Ethereum, the North Koreans hacked one of your cryptocurrency exchanges and you lost a Bitcoin after it had hit $20,000 USD (and you bought t…
Read more →A Canadian First – Battered Women’s Syndrome can help prove Due Diligence
Barrett Tax Law successfully litigated what could be a first in Canada. Using the defence of battered women’s syndrome to show L (shortened for privacy of client) never had the opportunity to file her taxes and exercised due diligence. In the case of R v. L. a woman was…
Read more →Vehicle Expenses
When a vehicle is used for both personal and business purposes, it is necessary to keep a log to record the business use of the vehicle. Please see our article on keeping a vehicle log found here: Unincorporated Business An unincorporated business may write off (deduct)…
Read more →Transfers of Property while Having a Tax Debt
Income Tax Act Subsection 160 ( http://laws-lois.justice.gc.ca/eng/acts/I-3.3/section-160.html ) Excise Tax Act Subsection 325 ( http://laws-lois.justice.gc.ca/eng/acts/E-15/section-325.html ) Subsection 160 and subsection 325 assessments are the most powerful collectio…
Read more →Transfer Pricing
Income Tax Act Subsection 247 Transfer prices are the prices at which services, tangible property, and intangible property are traded across international borders between related parties. Canada’s transfer pricing legislation requires, for tax purposes, terms and condit…
Read more →Tax Residency
Income Tax Act Subsection 250(1) Canada allows its citizens to be residents of Canada for tax purposes, and non-residents of Canada for tax purposes. This is an important distinction as a non-resident of Canada for tax purposes will only be subject to Canadian taxation …
Read more →GST/HST Small Supplier
Excise Tax Act s. 148 A small supplier is a supplier whose worldwide annual GST/HST taxable solutions are less than $30,000, or less than $50,000 for public service bodies. The supplies include zero-rated supplies, and includes the supplies of all associates. An importa…
Read more →Small Business Deduction
Income Tax Act subsection 125 The small business deduction is available on active business income for a Canadian Controlled Private Corporation. It provides a reduction in the corporate tax rate up to the federal limit of $500,000. What the above means is if you are ear…
Read more →Qualified Small Business Corporation Shares
Income Tax Act Subsection 110.6(1) and 110.6(2.1) In order to claim the lifetime capital gains exemption on a share sale, the shares must meet certain conditions to qualify for the special treatment. If the shares qualify, then the seller would be able to use his or her…
Read more →Qualified Fishing Property
Income Tax Act Subsection 110.6(1), 110.6(1.2), and 110.6(2.2) In 2015, the amount increased that a taxpayer can claim for the lifetime capital gains exemption as it relates to qualified fishing property. The amount is now $1,000,000. The definition of qualified fishing…
Read more →Principal Residence Exemption (PRE)
Income Tax Act s. 40(2)(b) The benefit of the principal residence exemption is obvious. The gain is not subject to tax if the property has been the individual’s principal residence for the entire time it has been owned by that individual. When you normally sell a proper…
Read more →Precious Metals
Income Tax Act subsection 123(1) A "precious metal" is a bar, ingot, coin or wafer of gold, platinum or silver that is refined to a purity level of at least: 5% in the case of gold and platinum; and 9% in the case of silver. If a “precious metal” is sold, then the sale …
Read more →Personal Services Business
Income Tax Act subsections 125(7) and 123.4(1) A personal services business (PSB) is a corporation that carries on business through an individual, and that individual performs services while actually acting like an employee. This is occasionally known as the incorporate…
Read more →Permanent Establishment
Income Tax Act Subsections 124(1) and 124(4) Income Tax Regulations subsection 400(2) A permanent establishment is a fixed place of business, which allows a certain jurisdiction to tax the income being made at that fixed place of business. The typical types of permanent…
Read more →Lifetime Capital Gains Exemption
Income Tax Act subsection 110.6 The Lifetime Capital Gains Exemption (LCGE) allows a taxpayer to receive $800,000 or $1,000,000 of otherwise taxable capital gains on a tax-free basis. The difference in tax-free amounts directly relates to the property that the gain rela…
Read more →Income Splitting Through Loans
Income Tax Act Subsection 74.5(2) Income Tax Regulations Subsection 4301(c) Income splitting is an attempt by one taxpayer to send taxable income to another taxpayer in a lower bracket. Typically this is done by splitting income between family members. Income splitting …
Read more →Illegal Income
Taxpayers are typically surprised to learn that income from illegal activities is still subject to tax here in Canada. The scenario usually plays out that someone is convicted of a crime (drug-dealing), and following this, that same individual is then audited for unrepo…
Read more →Gross Negligence Penalties
Income Tax Act Subsection 163(2), 163(3) If you, knowingly or under circumstances amounting to gross negligence, made a false statement or omission on your tax returns, the Canada Revenue Agency (“CRA”) may charge you with a penalty. The penalty is equal to the greater …
Read more →Gifts and Inheritances
In Canada, there will be no amount of taxes due from the receipt of a gift or inheritance in most circumstances. The giver of the gift may have a taxable event occur if they are gifting capital property. The gift will be deemed to have occurred at fair market value, and…
Read more →General Anti-Avoidance Rule (GAAR)
Income Tax Act Subsection 245 The General Anti-Avoidance Rule essentially states that where a transaction, or a series of transactions results in a reduction, avoidance, or deferral of taxes owing, and the transaction or the series of transactions are only being attempt…
Read more →Fraudulent Filing
Fiscal Arbitrators, Demara Consulting, and various other companies will tell you they know the secret to Canadian Income Tax. They will tell you they can file your returns in such a way that you will retrieve all taxes paid for the last 3, 7, or even 10 years. Should yo…
Read more →Directors Liabilities
Income Tax Act Subsection 227 Excise Tax Act Subsection 323 Typically in Canada, your debts are your own. However, where corporations are involved that is not always the case. The Canada Revenue Agency (“CRA”) can assess director’s of a corporation for certain kinds of …
Read more →Change in Use
Deemed Disposition Where there is a change in use of property (real estate), the owner of the property is deemed to have sold the property, and to have immediately re-purchased it. This occurs whether the change in use is from personal use to income producing, or from i…
Read more →Allowable Business Investment Loss
Income Tax Act Subsection 3(d), 38(c), 39(1)(c), 40(2)(g)(ii), and 50 An allowable business investment loss (“ABIL”) is half of a capital loss, which was incurred on the sale of shares, or a debt of a small business corporation. The importance of receiving and ABIL rath…
Read more →Active Business Income
Income Tax Act subsection 125(7) A Canadian Controlled Private Corporation’s first $500,000 of active business income is taxed at a much lower rate. This is known as the small business deduction. Active business income is essentially exactly what is sounds like. Active …
Read more →Canadian Controlled Private Corporation
A Canadian Controlled Private Corporation (or "CCPC") is a private corporation being controlled by Canadian residents. The definition strictly prohibits public companies from qualifying, and also those run by non-residents. The major benefit of being a CCPC is access to…
Read more →Attribution Rules
Income Tax Act subsections 74.1(1), 74.2(1), 74.5(2) The rules of attribution come into play when income-producing property is transferred or loaned to a non-arms length party with certain exeptions (directly or indirectly or by means of a trust). The income from the pr…
Read more →Employee v. IC
Many individuals choose to categorize themselves as an independent contractor (self employed) because of the various tax advantages. The Canada Revenue Agency has its own rules regarding whether a person is in a business relationship (independent contractor), or in an e…
Read more →Vehicle Expenses - Keeping a Log
If you use the same vehicle for business and pleasure, a logbook should be kept to identify the business, and personal use. If you are able to deduct vehicle expenses, then only the business portion can be deducted from income. If a business is providing you with a vehi…
Read more →Qualified Farm Property
Income Tax Act Subsection 110.6(1), 110.6(1.3), 110.6(2) In 2015, the amount increased that a taxpayer can claim for the lifetime capital gains exemption as it relates to qualified farm property. The amount is now $1,000,000. The definition of qualified farm property co…
Read more →Non-Taxable Income
You do not have to report certain amounts in your income, including the following: Any GST/HST credit or Canada child tax benefit payments, as well as those from related provincial and territorial programs ; Child assistance payments and the supplement for handicapped c…
Read more →CANADIANS LINKED TO THE PANAMA PAPERS
Below is the complete list of Canadian officers of entities associated with the Panama Papers. If your name is in the list below, it means that you have been linked to the Panama Papers. If you are affected, call Barrett Tax Law at 1-866-278-8424 or visit www.barretttax…
Read more →Hey Mr. Putin and Mr. Signumdur … We can help you with your Panama Papers tax problems
For most understanding tax matters can be a brain-numbing experience. With the recent stories of the Panama papers, it may be a challenge to truly comprehend what this international tax scandal is really about, why it affects Canada, and how the Canada Revenue Agency (“…
Read more →Scammers Impersonate Barrett Tax Law Employees
It has come to our attention that there are scammers claiming to be working with Barrett Tax Law, when in fact they do not. If you receive a call from a man named Timothy Rufus, claiming to be working with our firm, or calling from this phone number: (613) 366-5293, ple…
Read more →The Forgotten Tax: Withdrawing from US Dollar Accounts
The Canadian dollar has dropped more than 25% since only a short while ago when it was on par with the US dollar. As a result, not only has the cost of living increased dramatically, but also costs for those visiting the United States have skyrocketed. The depressed loo…
Read more →Watch out tax shelter participants: The CRA may be able to collect 50% of disputed amounts before the courts rule!
Many taxpayers have participated in tax shelters and donation schemes and have filed objections with respect to reassessments issued by the Canada Revenue Agency. Many of these objections are outstanding, and some are already before the courts. Generally when you file a…
Read more →Trouble Ahead for Taxpayers Involved in the GLGI Program
The Tax Court has concluded that the donation program known as Global Learning Gift Initiative (or “GLGI”) is in fact a “sham”. The GLGI website states that this program works as a “gifting arrangement tax shelter where Canadians are able to utilize available tax incent…
Read more →Eligible Dependant Tax Credit Requirements
If you’re a parent interested in the eligible dependant tax credit, then being aware of the rules and regulations is crucial. The reason why is quite simple. There are a number of rules involved in the eligible depend tax credit which could prevent you from eligibility.…
Read more →CRA Scams Continue Nationwide
Canadians beware: The RCMP has issued yet another warning about Canada’s ongoing tax scams. It has come to light that there are people impersonating Canada Revenue Agency employees in an attempt to steal your hard earned money. According to Global News Edmonton , “in th…
Read more →Government Toughens Up on Snowbirds
If you’re a Canadian who moves to a warmer country in the winter then beware of Canada’s new border exit-tracking system. CTV News reports that the federal government plans on cracking down on snowbirds that leave Canada for too long but still collect social benefits - …
Read more →Thinking of Purchasing a Franchise? Buyer Beware!!
If you are thinking of purchasing a franchise, it is imperative that you be protected and that you fully understand your rights and obligations prior to getting started. Although there are many perks to entering into a franchise, there are also heavy restrictions and hi…
Read more →The Canada Revenue Agency (“CRA”) is investigating KPMG for a tax avoidance scheme
In 2000, a wealthy B.C. family invested approximately $26 million in a KPMG tax product in the Isle of Man, a self-governing territory. This tax product was targeted for high net worth Canadian residents, resulting in the family paying close to no tax over several years…
Read more →DeMara Consulting Update
Donna Marie Stancer and Deanna Lynn Lavalley have been convicted of six fraud related charges after filing nearly $192-million in false expenses for themselves and 224 clients of their now closed Vernon tax preparation company, DeMara Consulting. Here at Barrett Tax Law…
Read more →Michael Citrome’s Article “A Defective GST/HST New Housing Rebate Claim Can Lead to Costly Tax Trouble”
August 31, 2015 - Michael Citrome's article 'A Defective GST/HST New Housing Rebate Claim Can Lead to Costly Tax Trouble' published in the Ottawa Business Journal touches on the issues that arise if you didn't give a lot of thought to the GST/HST New Housing Rebate. "If…
Read more →Income Splitting
Income Splitting is a tax planning strategy designed to shift income from a taxpayer paying a high rate of tax to another taxpayer paying tax at a lower rate. The Income Tax Act has many provisions attempting to limit income splitting, but you should be aware of the opp…
Read more →The Liaison Officer Initiative – Have you been asked to participate?
This summer, a number of small and medium-sized business owners have been asked by the Canada Revenue Agency (CRA) to participate in the Liaison Officer Initiative (LOI) - a part of the CRA’s 3-point plan to provide early tax compliance support to businesses. Through th…
Read more →Uber GST/HST Issue
Self-employed cab drivers are required by the Canada Revenue Agency to register, collect and remit HST/GST from their fares to the government. This requirement does not correspond to a certain amount of money being made by cab drivers. Rather, if you drive a cab as a se…
Read more →Michael Citrome's Article "Moving Provinces? Avoid a Tax Bill"
August 7, 2015 - Michael Citrome's blog post "Moving Provinces? Avoid Surprise Tax Bill" that was posted in the Ottawa Business Journal discusses the issues regarding income taxes and moving between provinces. "People move between provinces all the time. Here in Ottawa,…
Read more →Has your IRS filing deadline changed?
Many IRS filing deadlines have recently been changed by Congress, in H.R. 3236, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015. Effective as of December 31, 2015, if you are required to file with the IRS for your C corporation, partne…
Read more →How will the Budget 2015 affect your Foreign Income Reporting requirements?
The Department of Finance Canada’s Budget 2015 proposes to put into operation a new streamline reporting system for foreign assets. Presently, Canadian resident individuals, partnerships, corporations, and trusts that own a total value of more than $100,000 of specified…
Read more →Bitcoins: Are They Considered Specified Foreign Property?
If a Canadian taxpayer owns certain foreign property, the collective cost of which exceeds $100,000 CDN, the taxpayer must file a Form T1135 (Foreign Income Verification Statement). The Canada Revenue Agency (“CRA”) recently provided its views on whether digital currenc…
Read more →Dale Barrett was interviewed for Global News' 'Booming shared economy leaves governments of all levels scrambling to keep up on taxes'
July 22, 2015 - Global News reports on the issues surrounding taxes and companies such as Uber and Etsy in their "Booming shared economy leaves governments of all levels scrambling to keep up on taxes." See Dale Barrett's comments regarding the issue and planning ahead …
Read more →Tax Scam Update: DeMara Consulting Inc. has been found guilty of Tax Evasion
In 2010, Donna Marie Stancer and Deanna Lynn Lavalley started a tax consultation company by the name of DeMara Consulting Inc. It wasn’t until March of 2012 that the Canada Revenue Agency (the “CRA”) raided the DeMara Consulting Inc. office in downtown Vernon looking fo…
Read more →Cross-border Real Estate Planning: Have you done your due diligence?
Today, many Canadians own real property in the U.S. as vacation or rental property. There are various ways to hold such property, and the choice of how to hold your foreign real estate depends on the goal(s) you wish to achieve. Some of these goals may include avoiding …
Read more →First Court Decision on Provincial Residency of a Trust
Generally, the test applied to determine the residency of a trust is where its “central management and control” is located. The Newfoundland Supreme Court rendered a decision which recognizes the reality of the “trust” relationship. In Discovery Trust v. Minister of Nat…
Read more →Taking the CRA to Court
July 20, 2015 - The Ottawa Business Journal published a blog post written by Barrett Tax Law's Ottawa Managing Lawyer, Michael Citrome. "Here in Ottawa, many people think of the government as an employer, rather than as an obstacle to doing business. Even still, for man…
Read more →Tax Planning & The Solicitor-Client Privilege: Are You Covered?
There is a common misconception that all communications with a lawyer are privileged. A recent Federal Court case, Canada (National Revenue) v. Revcon Oilfield Constructors Incorporated, 2015 FC 524, is a reminder that not all communications with a lawyer are protected …
Read more →Dividends as Compensation to Shareholder/ Employees
Are you a shareholder of a non-arm’s length company and also employed for the same corporation? If so, you should think carefully before making an agreement where you are paid in dividends instead of being paid a salary or other form of compensation. If dividends are di…
Read more →Section 225.1 and Tax Shelters
With the passing of this new section, the Minister is now allowed to collect 50% of the amount assessed in respect of a tax shelter even if the related assessment is in dispute. Meaning even if you object, or appeal to Tax Court, the Minister can still come after you fo…
Read more →Is your agreement with the CRA binding?
Rosenberg v. Canada , 2015 FC 549 The taxpayer in the above noted case entered into an agreement with the CRA’s auditor. The CRA agreed not to reassess the 2006 and 2007 taxation year, except to make one specific adjustment. Three years later, the CRA commenced a second…
Read more →Tax Scam: Jason White
Have you received a call from someone calling themselves Jason White? He typically calls from 1-613-912-4377. This Jason White may be pretending to be a Canada Revenue Agency employee who claims there is a warrant out for your arrest. He then informs taxpayers that the …
Read more →FAPI (Foreign Accrual Property Income)
In Canada, residents are taxed on their worldwide income. Some Canadians think that they can invest in corporations outside of Canada, and because corporations are separate entities, there is no taxes to pay on the income the corporation is earning. While this can be co…
Read more →Group RRSPs
A Group Registered Retirement Savings Plan ("RRSP") is an employer-contribution retirement plan, that it similar to an individual RRSP. However, it is administered by the employer. The significant advantage to a Group RRSP is that contributions from your employer are ma…
Read more →Dale Barrett was quoted in "What to do if the CRA comes calling"
April 27, 2015 - Augusta Dwyer from The Globe and Mail wrote an informative piece on What to do if they CRA comes calling. Mr. Barrett suggests meeting with CRA staff in a neutral atmosphere free of details about the business owner’s personal life, such as vacation phot…
Read more →Barrett Tax Law in "Tax advice for entrepreneurs, no strings attached"
April 27, 2015 - Diane Jermyn from The Globe and Mail wrote a helpful article "Tax advice for entrepreneurs, no strings attached." Barrett Tax Law: This Toronto-based business offers a toll-free number throughout Canada (1-877-8-TAX-TAX) where small business owners, the…
Read more →Dale Barrett was quoted in Yahoo Finance's article "Can the CRA use your social media accounts against you?"
April 24, 2015 - Andrew Seale from Yahoo Finance wrote a riveting article on whether or not the CRA can use your social media accounts against you. Of course, technically and ethically, they should start by looking at your books and records to determine how much you’re …
Read more →Barrett Tax Law in "Be Prepared When Canada Revenue Agency Comes Calling"
April 18, 2015: Brian McCullough from National Post wrote a very informative article "Be Prepared When Canada Revenue Agency Comes Calling" Tax lawyer Dale Barrett has one simple question for small-business owners and self-employed people who run afoul of the Canada Rev…
Read more →How to Hold Title to Property Ownership in Florida to Avoid Ancillary Probate
Many Canadians who own property in Florida are inadvertently bound by Florida probate law. This means that upon the death of a Canadian or nonresident, if real property was owned and located in Florida, ancillary probate is required by Florida State Law despite having a…
Read more →Capital Gains Exemption for Qualified Small Business Corporations
The Lifetime Capital Gains Exemption is a tax planning technique that is available to business owners who are selling shares of their private companies. This is an economic incentive to help raise the level of investment in small businesses, however, not everyone meets …
Read more →Reporting Foreign Property
Form T1135 – Foreign Income Verification Statement Are you a Canadian resident who is an individual, corporation, partnership, or trust? If so, you are required to report holdings of Specified Foreign Property that, collectively, costs $100,000 or more at any time durin…
Read more →Jeopardy or Collection Orders
If a taxpayer does not agree with an assessment from the Canada Revenue Agency (“CRA”), there are a number of avenues the taxpayer may explore to dispute the assessment. Once an assessment is in dispute, the taxpayer usually does not have to pay the amount in dispute un…
Read more →Yet Another CRA Tax Scam to be Aware of
With the growth of technology has come an increase with ways in which scammers can reach victims. Within the past few weeks we have been made aware of an email that has been going around claiming that they are the Canada Revenue Agency (the “CRA”). If you have received …
Read more →Income From Illegal Activities
Canadians are always surprised to learn that an illegal business must pay tax on its income. Be it drugs, prostitution, theft, etc., the Canada Revenue Agency (the “CRA”) still wants their cut. If a taxpayer is caught committing a criminal act they will obviously be bro…
Read more →Real Estate Audits
Have you bought and sold a new condo over the past seven years? The Canada Revenue Agency (“CRA”) has deployed abusive audit practices and has been targeting the booming real estate markets in Toronto and Vancouver. The focus of this audit trend is primarily on individu…
Read more →Is now a good time to come forward to the IRS?
U.S. Citizens worldwide have recently learned, especially through the enactment of FACTA, that they have a responsibility to come forward to the IRS. U.S. Citizens, whether residents or non-residents, dual citizens, and even non-U.S. Citizens who are deemed U.S. Residen…
Read more →Do you have assets, investments or a savings account outside of Canada?
If you are a Canadian with offshore property and/or income, be advised that there are new reporting requirements due to changes imposed by the federal government. There have been signs to indicate that they are serious about making people pay. It is important to note th…
Read more →Spike in the Number of Nurses being Audited
I have seen a huge spike in the number of nurses being audited. The number has increased dramatically over the last year. The CRA is steadfast in going after the homecare sector and appears to be attempting to disallow virtually all of their deductions – despite the fac…
Read more →The CRA is Financially Destroying Victims of Tax Scams
The Canada Revenue Agency is financially destroying victims of tax scams through the imposition of gross negligence penalties! You may have fallen victim to a tax scam, or perhaps one of your family members, friends or co-workers has been victimized. After a wave of tax…
Read more →Dale Barrett’s Book is on Amazon’s Bestseller list for the millionth week in a row!
March 16, 2015: For the millionth week in a row Dale Barrett’s book is featured on Amazon’s bestsellers list. No other Canadian tax lawyer’s book appears in the top 100! Tax Survival for Canadians: Stand up to the CRA, which was published in March 2013, ranks 7th in tax…
Read more →Have you ever wondered whether you are getting correct advice from the CRA?
Have you ever phoned the Canada Revenue Agency seeking advice or clarification about an important tax matter? Have you ever wondered whether you are getting correct advice? Well a recent internal survey (conducting by the government itself) asking that very question pro…
Read more →Barrett Tax Law was referenced in the Yahoo Finance article, " What happens when your tax return gets audited"
February 23, 2015: Gail Johnson from Yahoo Finance wrote a useful article on "What Happens when your tax return gets audited" According to Barrett Tax Law , the CRA performed more than 370,360 audit and review actions in the 2008-09 tax season. During that period, it co…
Read more →Barrett Tax Law was quoted in CBC’s article “10 ways to attract a CRA auditor’s attention”
March 2, 2015: Tom McFeat, from CBC News, wrote a very informative article on how to attract a CRA auditor's attention. The tax department "has tools to investigate and gather information about your industry," says Barrett Tax Law . "If your numbers don't fit the typica…
Read more →Dale Barrett's contribution to the Toronto Star's tax article, "7 triggers that may lead to a tax audit"
May 19, 2013: Business reporter, Madhavi Acharya-Tom Yew, of the Toronto Star, wrote a useful article informing readers of the common triggers that increase the likelihood of a CRA tax audit, which are: Being self-employed Any big changes Recurring losses Big expenses N…
Read more →April 23, 2013: BNN (Business News Network) news broadcast: "Surviving a tax audit: Debunking CRA myths"
Canadian tax lawyer at Barrett Tax Law, Dale Barrett, looks at the various myths many Canadians have about the Canada Revenue Agency in this informative interview on the Business News Network. The first myth debunked is "The CRA will not find out what I have not told th…
Read more →Financial Post article: "How to handle tax audits — and how to avoid them in the first place"
April 13, 2013: Dale Barrett of Barrett Tax Law provided Financial Post reporter, Melissa Leong, with effective tax tips for avoiding CRA tax audits: "You face a higher risk of being audited if you are self-employed or in an industry with a lot of cash transactions such…
Read more →Tax Survival for Canadians: Stand up to the CRA, a valuable tax resource written by Canadian tax lawyer Dale Barrett and published by Self Counsel Press, is now available for purchase!
If you are currently involved in a tax dispute with the Canada Revenue Agency or if you're simply looking to be proactive and avoid tax problems with the often heavy-handed CRA, Tax Survival for Canadians: Stand up to the CRA , is a useful tax guide (and interesting rea…
Read more →Vancouver Sun investigates Jeff Eshun of DSC Lifestyle Services
February 16, 2013: David Baines, reporter at the Vancouver Sun, continues his investigation of Jeff Eshun, owner of JV Raleigh Superior Holdings Inc. who has been fined $6.95 million by the B.C. Securities Commission and consequently banned from selling investment notes…
Read more →ATTENTION WINDSOR, ONTARIO COMMUNITY! Free Emergency Tax Seminar on Wednesday, February 27 at 6:30pm
In light of events recently reported in the media regarding tax savings schemes that have instead resulted in significant tax reassessment bills and penalties issued by the Canada Revenue Agency to many hardworking residents of Windsor , Dale Barrett, Canadian tax lawye…
Read more →Dale Barrett's book, Tax Survival for Canadians: Stand Up to the CRA, is now available for purchase on Amazon.ca
Canadian tax lawyer and principal at Barrett Tax Law, Dale Barrett, had his book published, Tax Survival for Canadians: Stand up to the CRA, by Self-Counsel Press and is now available for purchase on Amazon.ca. This valuable tax resource explains how hardworking Canadia…
Read more →Members of the Peterborough and Kawarthas Association of Realtors will be given a special tax seminar presented by Dale Barrett, Canadian tax lawyer and principal at Barrett Tax Law
Dale Barrett, Canadian tax lawyer and principal at Barrett Tax Law, will be presenting an informative tax seminar to members of the Peterborough and Kawarthas Association of Realtors at their annual general meeting to be held at the Peterborough Golf and Country Club on…
Read more →The Windsor Star interviews Dale Barrett from Barrett Tax Law regarding the Fiscal Arbitrators tax program
Dale Barrett, Canadian tax lawyer at Barrett Tax Law, was interviewed for an article published in the Windsor Star on February 12, 2013 regarding the Fiscal Arbitrators tax program. Barrett Tax Law is currently defending approximately 200 taxpayers across Canada against…
Read more →Attention Kincardine community & surrounding areas:
October 7, 2012 Dale Barrett, expert tax lawyer and principal at Barrett Tax Law, will be giving a free seminar this Saturday, October 13th for Canadians concerned about illegal tax schemes. The seminar, How to Protect Yourself from Fraudulent Tax Schemes, consists of a…
Read more →Article as published in the Canadian Real Estate Wealth magazine: "The dreaded Canada Revenue Agency tax audit: tax tips for the self-employed"
Dale Barrett, expert tax lawyer and owner of Barrett Tax Law, briefly explores strategies on avoiding as well as facing a tax audit. Does the CRA target small business owners and the self-employed? The CRA focuses on the groups who are more likely to omit or misrepresen…
Read more →Canada: Safe to Apologize
Canada: Safe to Apologize Article by Dale Barrett and Barry Leon, November 8, 2006 Originally published in Mediation Committee Newsletter , September 2006 The province of British Columbia is the first Canadian jurisdiction to introduce a law providing a safe harbour for…
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