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Overview: When the CRA’s Conduct Increases the Cost of Tax Litigation

In Canada v. Marine Atlantic, the Federal Court of Appeal considered an important issue about court costs, fairness in litigation, and the conduct expected from the CRA during tax disputes. The decision in Canada v. Marine Atlantic is significant because it confirms that courts may order s...


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Overview – A Toronto Business Owner, the COVID-19 Pandemic, and the Canada Emergency Rent Subsidy Program

Milne v The King is a 2026 decision from the Tax Court of Canada regarding taxpayer eligibility for the Canada Emergency Rent Subsidy (“CERS”) program in which the taxpayer operated a business out of a dedicated portion of his home. The central issue before ...


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The recent decision in C&W Offshore Ltd. v. HMK, 2026 TCC 40, serves as a stark reminder to Canadian businesses of the rigorous obligations imposed by Part XIII of the Income Tax Act (ITA) when dealing with non-resident suppliers. The case centered on two primary issues: first, whether rental payments for industrial subsea equipment made to a United King...


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Overview: How the CRA may deal with incomplete or unreliable tax records

The case of Karlozian v. The King deals with an important issue in Canadian tax law: how the Canada Revenue Agency (CRA) determines unreported income when a taxpayer’s records are incomplete or unreliable.

The case also examines when penalties for serious tax misco...


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Overview of Canadian Regulatory Framework for Foreign Exchange Businesses

Foreign exchange bureaus operating in Canada are subject to a comprehensive compliance regime under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), administered primarily by the Financial Transactions and Reports Analysis Centre of Canada, alongside tax reporting obligati...


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