Tax Page

David Rotfleisch Shares Expert Insights in Global Law Experts Q&A

We are pleased to share a recent Q&A featuring David Rotfleisch, Canadian tax lawyer and founding tax lawyer of Tax Page, in collaboration with Global Law Experts (GLE).

During the interview, David discusses Taxpage’s experience helping taxpayers navigate complex Canadian and international tax matters, including:

• Cryptocurrency taxation
• Canada’s departure tax
• Immigration and emigration tax planning
• CRA offshore audits
• Cross-border tax matters

David also shares the example of a taxpayer whose offshore audit continued for approximately 10 years despite the taxpayer having disclosed the foreign assets and filed Form T1135.

The discussion highlights the importance of obtaining experienced legal guidance when dealing with complex tax reporting, relocation, cryptocurrency investments or disputes involving the CRA.

To watch the full interview here: See Comment

Questions about cryptocurrency taxation, departure tax or cross-border tax matters?

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📩 [email protected]

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Can the CRA Reassess You After Giving You Incorrect Tax Advice?

Yes.

Receiving incorrect tax advice from the CRA does not necessarily prevent a reassessment.

One piece of advice we consistently give taxpayers is simple: don't rely on the CRA's general enquiries line for tax advice.

Recent reports from Canada's Auditor General and the Taxpayers' Ombudsperson reinforce exactly why. The Auditor General found that CRA telephone agents answered only 17% of tested tax questions accurately.

Despite those findings, Canadian taxpayers remain legally responsible for filing accurate tax returns. In most cases, the CRA is not legally bound by incorrect advice provided through its general enquiries line.

If you've been reassessed after relying on incorrect CRA advice, you may still have legal options, including:

1. Applying for taxpayer relief to request the cancellation or waiver of interest and penalties.

2. Filing a Notice of Objection to dispute the reassessment.

3. Challenging gross negligence penalties where appropriate.

If you contact the CRA, keep detailed records of every conversation, including the date, the agent's name or identification number (if provided), and the advice you received.

One important point: General telephone advice from the CRA is not legally binding. If certainty is required, seek independent professional tax advice or determine whether a formal Advance Income Tax Ruling is appropriate.

Read our full analysis:
https://taxpage.com/articles-and-tips/cra-agents-answer-only-17-of-tax-questions-accurately-what-canadian-taxpayers-must-know-about-the-auditor-general-and-ombudsperson-reports/

Need help responding to a CRA reassessment?

📞 416-367-4222 for FREE 10-minute consultation

📧 [email protected]

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Disclaimer: Posts on this page are for educational purposes only. Not ≠ tax or legal advice.

Can Canadian Taxpayers Legally Choose Not to Pay Tax?

Recent headlines surrounding King Charles III's voluntary payment of personal income tax have revived a familiar misconception: that paying income tax is optional.

In Canada, it is not.

King Charles recently disclosed that he voluntarily paid £12.9 million in personal income and capital gains tax for the 2024/25 tax year. While the British monarch's tax arrangements arise from the United Kingdom's unique constitutional framework, they do not change the legal obligations of Canadian taxpayers.

Canada's tax system is built on voluntary compliance, not voluntary taxation.

Canadian taxpayers are legally required to report income, file tax returns, and pay taxes owing under the Income Tax Act. Courts have consistently rejected arguments that paying income tax is a matter of personal choice.

Acting on misinformation can result in serious consequences, including:

✅ Reassessments and interest.

✅ Gross negligence penalties.

✅ In cases of intentional tax evasion, criminal prosecution, substantial fines, and imprisonment.

The key takeaway: The King's tax disclosure is an interesting constitutional development in the United Kingdom, but it has no effect on the legal obligations of Canadian taxpayers.

To read our full analysis: See Comment

Have questions about your Canadian tax obligations?

📞 416-367-4222 - FREE 10-minute consultation

📧 [email protected]

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Think your home listing is just marketing? The CRA may see it very differently.

If you're buying, renovating, or selling residential property, what you say about it publicly could matter more than you think.

The CRA is increasingly reviewing MLS listings and other third-party information when assessing real estate transactions. Details describing renovations, investment potential, or resale value may be considered alongside ownership history and other evidence when evaluating a taxpayer's intentions.

Here are three important things every homeowner, renovator, and real estate investor should know:

1. 🏡 Your property listing could become part of a CRA audit.

MLS descriptions and listing history may be reviewed when determining whether a property was held for personal use, investment, or resale.

2. ⚖️ You don't have to be a developer to face builder-related GST/HST issues.

Substantial renovations, repeated property transactions, or buying with the intention of resale may expose taxpayers to builder classification under the Excise Tax Act.

3. 💰 The financial consequences can be significant.

Builder classification may trigger GST/HST based on the fair market value of a property. In some situations, the self-supply rules can create GST/HST liability even where no conventional sale has taken place.

Tax tips:

• Keep records that clearly support your intended use of the property.

• Consider your GST/HST obligations before buying, renovating, or selling.

• Seek experienced tax advice early if there's any uncertainty about your tax position.

Read our full analysis here:
https://taxlawcanada.com/cra-real-estate-tax-audits-using-mls-data-builder-risk-gst-hst-exposure-audit-defence-strategies-in-canada/

Need help responding to a CRA real estate tax audit?

📞 416-367-4222 | FREE 10-minute consultation

📧 [email protected]

Taxpage.com

All the tax help you need.

Canada Day is a time to celebrate the people, communities, and values that make Canada such a wonderful place to call home.

Today, we celebrate the diversity, resilience, and shared spirit that bring Canadians together from coast to coast.

From all of us at Taxpage, we wish you and your loved ones a safe, happy, and memorable Canada Day.

Happy Canada Day! 🇨🇦

Taxpage.com

All the tax help you need.

Congratulations, Osinachi Obi-Njoku!

We are delighted to congratulate Osinachi Obi-Njoku on his appointment as an associate at Rotfleisch & Samulovitch P.C.

After successfully completing his articling term with the firm, Osinachi begins this next chapter with valuable experience across a broad range of tax matters, including tax litigation, CRA disputes, voluntary disclosures, and tax planning.

We are proud to see Osinachi continue his legal career with our firm and look forward to his ongoing contributions to our clients and team.

Learn more about Osinachi and his background on our Leadership Team page: See Comment for link.

Please join us in congratulating Osinachi on this well-deserved milestone!

Taxpage

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Making Money During the World Cup? The CRA May Want Its Share

As Canadians celebrate the Canadian men's national team's strong start to the 2026 FIFA World Cup and prepare for tomorrow's match against Switzerland in Vancouver, many may be overlooking an important issue: income earned during the tournament is generally taxable.

Canada may be hosting the FIFA World Cup, but there is no special tax exemption for World Cup-related income. Whether you're renting out your home, charging for parking, selling merchandise, reselling tickets, or earning sponsorship revenue, the same Canadian tax rules generally apply.

Some World Cup-related activities that could trigger tax implications include:

• Short-term rental of rooms, apartments, or principal residence units
• Charging for parking spaces or driveways near stadiums or fan zones
• Food and beverage sales around event locations
• Merchandise sales
• Ticket resales above face value
• Watch parties or event-hosting income
• Content creation, sponsorships, and influencer earnings tied to the event
• Athlete endorsement and sponsorship income
• Transportation or shuttle services for visitors
• Sports betting activity that rises to a commercial or organized level

If an activity becomes frequent, organized, or profit-driven, the CRA may consider it a business. Depending on the circumstances, additional obligations may apply, including record-keeping requirements and GST/HST registration.

Key Takeaway

The World Cup presents real income opportunities for Canadians. However, taxpayers who treat tournament income as a tax-free windfall rather than reportable income may expose themselves to reassessments, penalties, and interest. In more serious cases, gross negligence penalties can reach 50% of the understated tax.

Read our full analysis:
https://taxpage.com/articles-and-tips/fifa-world-cup-2026-and-canadian-tax-what-short-term-renters-businesses-and-bettors-need-to-know/

Need help with a tax issue?

📞 416-367-4222

📩 [email protected]

FREE 10-minute consultation (Canada only)

Follow us for major tax updates in Canada.

Taxpage.com

All the tax help you need.

CRA Delays Under Review: What Taxpayers Need to Know

A recent Reddit post highlighted the frustrations some taxpayers experience when dealing with CRA processing delays.

According to the post, a taxpayer expecting a spousal support refund was asked to provide bank statements, e-transfer records, and later court documents. Despite submitting the requested information, the review reportedly continued for several months.

Concerns about CRA processing delays have become increasingly visible among taxpayers and tax professionals. In response, the Taxpayers' Ombudsperson has launched a formal review of the CRA's processing times and administrative backlogs.

However, there are significant limitations to challenging CRA delays:

• The Ombudsperson cannot compel the CRA to resolve individual cases or enforce specific timelines.

• Taxpayers cannot use a Notice of Objection or appeal to speed up processing delays.

• Judicial review is only available in limited circumstances involving serious procedural fairness concerns.

• In most cases, there is no direct compensation or remedy for delay-related financial loss or inconvenience.

This reflects a broader issue in Canadian tax administration.

"The Canadian tax system imposes strict compliance obligations on taxpayers, yet offers very limited recourse when the CRA fails to meet comparable service standards," says David Rotfleisch, Managing Partner at Taxpage.

Given these limitations, CRA delays must often be managed strategically rather than reactively.

Tax Tips

1. Ensure submissions are complete and well-documented to reduce the likelihood of additional information requests.

2. If delays are creating significant financial consequences, seek professional advice regarding available escalation options and procedural remedies.

3. Consider the Voluntary Disclosures Program where outstanding compliance issues exist.

4. Consult an experienced Canadian tax lawyer before issues escalate into larger disputes.

Read our full analysis here:

https://taxlawyer.com/cra-delays-under-formal-investigation-limited-remedies-for-taxpayers-facing-administrative-backlogs/

Need help dealing with CRA delays?

📞 416-367-4222
📩 [email protected]

FREE 10-minute consultation (Canada only)

Taxpage.com

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As Juan Carlos Diaz recently completed his articling term with Tax Page, we'd like to take a moment to reflect on his experiences, contributions, and the lessons he gained throughout the past year.

Throughout his time with the firm, Juan approached his work with dedication, professionalism, and a thoughtful approach to complex tax matters.

Reflecting on his experience, Juan shared:

*"This articling experience taught me how to apply legal principles to real factual situations in a practical and strategic way, including how legal issues are approached from both a technical and practical perspective.*

*Working on Voluntary Disclosures Program (VDP) matters involving cryptocurrency taxation was highly valuable, exposing me to current and evolving areas of law.*

*I am incredibly grateful for the mentorship from David Rotfleisch and Kevin, whose guidance helped me improve my research skills, develop a more structured analytical approach, and become more comfortable working with complex tax issues."*

When asked what advice he would offer future students, Juan noted:

*"Ask questions consistently, seek feedback regularly, and never hesitate to ask for guidance when needed. At Taxpage, the lawyers are very supportive, and making the most of that mentorship will significantly improve your confidence and legal skills."*

We thank Juan for his hard work and contributions throughout his articling term and wish him continued success in his legal career.

Taxpage.com

All the tax help you need.

Part I: What Canadians Must Know About CRA Cryptocurrency Tax Disputes

A CRA cryptocurrency audit can quickly become much more than a request for information.

Depending on the CRA's findings, an audit may lead to a reassessment, penalties, a formal objection, or even litigation before the Tax Court of Canada.

As cryptocurrency tax enforcement continues to evolve, it is important for taxpayers to understand how these disputes develop and what steps can be taken to protect their rights.

Here are three key points to know:

1. CRA cryptocurrency audits increasingly rely on blockchain analytics, wallet tracing, exchange records, and third-party reporting to review taxpayer activity.

2. A reassessment may recharacterize reported losses, deny deductions, or impose penalties depending on how the CRA views a taxpayer's transactions and intentions.

3. Taxpayers generally have only 90 days from the date of a reassessment to file a Notice of Objection. Missing this deadline can have serious consequences.

Tax Tips:

• Keep detailed records of all cryptocurrency transactions and trading activity.

• Document your intentions when acquiring and disposing of digital assets.

• Treat every CRA cryptocurrency audit seriously and respond promptly to requests for information.

• Do not ignore a reassessment. Early action can make a significant difference in preserving your rights.

Read Part I of our 5-part series on Canadian cryptocurrency tax disputes: See comment for link.

In Part II, we will explore how evidence can shape the outcome of a cryptocurrency tax dispute and what taxpayers can do to strengthen their position.

Need help with a CRA cryptocurrency audit, reassessment, or tax dispute?

📞 Call 416-367-4222 for a FREE 10-minute consultation.

📩 Email: [email protected]

Taxpage

All the tax help you need.

Disclaimer: Posts on this page are for educational purposes only and should not be taken as tax or legal advice. For legal advice, please consult a lawyer.