Article & Tips
Case Comment: Recent Tax Court Decision Balances CRA’s Broad Reassessment Powers While Placing Limits on Gross Negligence Penalties, 3278735 Nova Scotia Limited v His Majesty the King, 2026 TCC 65 GalleryCase Comment: Recent Tax Court Decision Balances CRA’s Broad Reassessment Powers While Placing Limits on Gross Negligence Penalties, 3278735 Nova Scotia Limited v His Majesty the King, 2026 TCC 65
Case Comment: Recent Tax Court Decision Balances CRA’s Broad Reassessment Powers While Placing Limits on Gross Negligence Penalties, 3278735 Nova Scotia Limited v His Majesty the King, 2026 TCC 65
This 2026 decision of the Tax Court of Canada addresses two recurring issues in tax administration and enforcement: 1) the scope of the CRA’s power [...]
Beware the Tax Trap: When Exactly Does a Business Cease to Qualify as a “Small Supplier” and Lose GST/HST Exemption?
Overview: GST/HST Obligations for Canadian Businesses & The Small-Supplier Exemption Section 165 of Canada’s Excise Tax Act imposes GST/HST on “every recipient of a taxable supply made [...]
GST/HST Bad Debt Deductions Denied for Failing to Meet Strict Statutory Requirements, Heydary Green Professional Corporation v. The King
Overview – GST/HST Bad Debt Deductions and the High Cost of Technical Non-Compliance In Heydary Green Professional Corporation v. The King, the Tax Court of [...]
Bergevin v. The Queen – Missed a Tax Deadline? Disaster! The Courts Are Very Strict with Procedural Rules
Introduction: Missed the Tax Deadline? The Tax Court May Not Give You a Second Chance The case of Bergevin v. The Queen deals with an [...]
Ambiguous HST Clauses in Real Estate Transactions: When “Tax Included” Means Risk Assumed
Real property owners in Canada should be aware that their tax obligations may differ depending on whether a property is used for residential (such as [...]
Charging GST/HST on Digital Marketing Income in Canada: AdSense, NFTs, and Zero-Rating Risks
Introduction – GST/HST Risks on Digital Marketing Income: Common Misconceptions and CRA Reassessments Canadian taxpayers, including content creators, influencers, and digital entrepreneurs, who earn income [...]
GST carousel fraud not a fun ride when CRA catches up to you – guidance from a Canadian tax lawyer
New Zealand tax fraudster penalized for GST fraud A New Zealand court has ordered Gisborne farmer John Bracken, the country’s largest tax fraudster, and his [...]
Tax Court of Canada Overturns CRA’s Denial of GST/HST Input Tax Credits: Fiera Foods Company v The King
Introduction – Tax Court of Canada Clarifies CRA Authority to Deny GST/HST Input Tax Credits During a CRA Tax Audit The decision in Fiera Foods [...]
Case comment – Heritage Square Retirement Living Inc. v The King, 2026 TCC 39
CRA denied the taxpayer’s application for GST/HST rebate due to late filing—an $84,000 mistake The taxpayer operated a personal care home in Newfoundland and Labrador [...]