Tax Planning

Tax planning for business or for individuals and families is an ongoing process to reduce the overall taxes owing by the business and ultimately by the owners and family. When setting up and running a business a team

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Tax Audits, Problems & Representation

A CRA audit is the start of the tax investigation and a Canadian taxpayer needs professional representation from the start. Never speak to CRA by yourself. Always have your Canadian tax lawyer deal with CRA on your behalf.

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Voluntary Disclosure

The voluntary disclosure program allows you to avoid prosecution or penalties for unreported income or offshore assets by having one of our Canadian tax amnesty lawyers approach CRA on your behalf before they approach you.

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Unpaid Tax Debt and CRA Garnishment

The CRA can send a garnishee notice to your employer or can even seize your bank accounts if you owe them taxes. In many cases you will find yourself bankrupted while making payment arrangements.

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Fight CRA

CRA can and does lien salary and seize assets and bank accounts without a court order. CRA can and does show up at your home and place of business. Our top Canadian tax lawyers will protect your rights and will fight for you.

Rotfeisch & Samulovitch PC

Taxpayer Relief (Fairness Application)

In some limited circumstances CRA will eliminate or reduce interest or penalties that they have charged you. A taxpayer relief application (fairness application) can be submitted when circumstances out of your control resulted in penalties and interest owing to the Canadian tax department. Read more

Rotfeisch & Samulovitch PC

Tax Court Appeals

Once a Notice of Confirmation from the Canada Revenue Agency confirming the audit assessment is received, the next level of disputing a tax assessment/reassessment is to have your Canadian Tax Litigation Lawyer file a Notice of Appeal with the Tax Court of Canada.

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Did you know that you can go to jail for tax crimes, including unfiled tax returns? If CRA has not approached you then you may qualify for the voluntary disclosure program.If CRA has started an investigation, or you been charged with a tax crime such as tax evasion or have received a summons (prosecution) for unfiled tax returns our experienced Canadian tax litigation lawyers can help you. Read more
Tax Shelters are generally investments that have as a main or secondary purpose the reduction of taxes, and are often challenged by CRA. The Canadian tax department has been warning about charity tax shelters for years, and has tried various approaches to shutting down the charity tax shelter industry.Read more
Taxpayers are often overwhelmed by a tax assessment or a Tax Statement of Account that shows a balance owing that is impossible to pay. One common reaction is to ignore it since you can’t afford to pay. Read more
Stock options are usually granted to employees to give them more motivation in helping with the success of the business. They are sometimes called golden handcuffs. The Income Tax Act encourages employee stock options by granting them favorable tax treatment. Read more

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If you have not filed your Canadian tax returns, or if you have filed them and CRA believes that you have not reported all of your income, they may issue a new worth assessment. They take two financial snapshots, one at the start of the audit period and one at the end. They add your reported income and expenditures to the opening financial position and subtract loans. If the amount is less than your closing net worth they will assess you for tax, penalties and interest on the difference. Net worth assessments require an understanding of the accounting behind the CRA calculations and the proper inclusions and exclusions from the opening and closing balances. Our firm has a track record of fighting these assessments.

You may be liable for someone else's taxes. CRA can assess Canadian taxpayers under section 160 of the Income Tax Act for the tax liability of another party. This occurs in situations where a taxpayer who owes taxes transfers assets such as a house or money to a related party, usually a relative such as a spouse or child. CRA will issue an assessment against the relative who receives the property for the taxes owing by the transferor. CRA collections officers will then proceed to enforce the taxes owing, and will often lien the house. The s.160 assessment can be challenged by filing a Notice of Objection within 30 days. The taxes owing by the asset transferor can be challenged as part of the Objection process.

Income Tax Debt

A CRA tax debt has to be addressed immediately. If it is ignored a CRA collections officer will commence tax enforcement actions. This means your bank account will be seized, your wages or accounts receivable or rents will be garnished, and your house may have a lien registered.Read more

Tax Audit Assistance

There are over 350,000 audit and review actions conducted by the Canada Revenue Agency on a yearly basis. Around 15,000 of these audits deal with “cash only” businesses (i.e. the underground economy). Additionally, an estimated 35,000 are tax shelter audits.Read more


A Canadian taxpayer’s income tax bracket and therefore the income tax liability depends on the absolute amount of the taxpayer’s income because the higher the income the higher the income tax bracket and the percentage of income tax paid. Income splitting is a tax planning strategy whereby one taxpayer transfers a portion of his/her own income to another taxpayer who is taxed at a lower tax rate. There are various income splitting techniques that can be used.Read more


A small business owner can often income split with a spouse by employing the spouse in the business as a T4 employee or by having the spouse own shares of the corporation and receive dividends. Any salary paid must be reasonable and supported by the actual work done. A written employment agreement is very advisable. If the spouse or children are going to own shares of the business, care must be taken to avoid the income tax attribution rules that attribute income or capital gains on the property back to the spouse who originally owned the assets.Read more

Tax Tips

Nov. 2015
GLGI Tax Shelter Decided Against Taxpayers

The Tax Court of Canada case of JUANITA MARIANO vs. HER MAJESTY THE QUEEN 2009-3506(IT)G was decided against the taxpayers who invested in a donation tax...

Nov. 2015
Estate Charitable Donations

A graduated rate estate (GRE) can claim a donation in the year it is made or carry back the donation to the year of death & forward 5 years after being made....

Nov. 2015
Jail Sentence and Fine for Tax Fraud

In the case of R. v Wang 2015 BCPC 302 the British Columbia Provincial Court sentenced the defendant who had pled guilty...

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