Tax Page

Tax Page A Toronto-based boutique Canadian Tax Law firm specializing in income tax and business law.

Rotfeisch & Samulovitch PC is a Toronto-based boutique Canadian Tax Law firm specializing in income tax and business law. By staying small and specialized, we are able to respond quickly and effectively to our client's income tax issues and concerns as they arise. There's just one answer to a tax problem – an effective tax solution that's just right for you.

CRA Delays Under Review: What Taxpayers Need to KnowA recent Reddit post highlighted the frustrations some taxpayers exp...
06/17/2026

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

All the tax help you need.

As Juan Carlos Diaz recently completed his articling term with Tax Page, we'd like to take a moment to reflect on his ex...
06/17/2026

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 DisputesA CRA cryptocurrency audit can quickly become much...
06/11/2026

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.

Meet Evgeniia PredannykovaTax Page's Law Clerk“One mistake could have a profound impact on everything that follows.”Arou...
06/09/2026

Meet Evgeniia Predannykova

Tax Page's Law Clerk

“One mistake could have a profound impact on everything that follows.”

Around the office, she's simply Gina. Since joining the firm in May 2023, she has become one of the dependable forces behind Taxpage's legal team and a valued source of support for both colleagues and clients alike.

Known for her exceptional attention to detail and resourcefulness, Gina approaches every challenge with the belief that there is always a solution to be found.

One memorable example involved tracking down critical documents that others had been unable to locate, helping move a client matter forward when it mattered most.

Her positive attitude, reliability, and commitment to getting things right continue to make her an important part of the Taxpage team.

Thank you, Evgeniia, for everything you do.

Fun Fact: Gina enjoys cooking and nearly attended culinary school before pursuing a career as a law clerk.

To learn more about Gina, see the comment.

Taxpage

All the tax help you need.

GST/HST: How a Taxpayer Lost $83,850 Paying Taxes They Didn’t OweImagine paying GST/HST you never owed, only to discover...
06/08/2026

GST/HST: How a Taxpayer Lost $83,850 Paying Taxes They Didn’t Owe

Imagine paying GST/HST you never owed, only to discover that a missed deadline prevents you from getting all of it back.

That is exactly what happened to a personal care home in Newfoundland and Labrador.

The taxpayer mistakenly paid GST/HST on tax-exempt residential rent and ultimately proved that the tax had been paid in error. However, by the time the rebate application was filed, part of the claim had fallen outside the statutory deadline.

The result?

Although the CRA refunded approximately $240,000, an additional $83,850 was denied because the rebate claim was submitted too late.

The taxpayer appealed, arguing that the outcome was unfair.

The Tax Court disagreed.

The Court confirmed that the two-year GST/HST rebate deadline is strict and leaves little room for relief, even where the taxpayer was otherwise entitled to a refund.

Tax Tips:

• Always confirm whether a supply is taxable or exempt, particularly in real estate and rental arrangements.

• Being correct on the tax law is not always enough. Missing a statutory deadline can permanently eliminate an otherwise valid claim.

• A tax remission order may provide relief in exceptional circumstances, but it is a rare remedy and should generally be viewed as a last resort.

• Where significant amounts or statutory deadlines are involved, obtaining professional advice early can help preserve available options and avoid costly mistakes.

Want to learn more about this case and the strict GST/HST rebate rules involved? See the comment for link to our full analysis.

Need help recovering a denied GST/HST rebate? Our team of experienced Canadian tax lawyers can help.

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

📩 Email: [[email protected]](mailto:[email protected])

Taxpage

All the tax help you need.

3 Tax Updates Canadians Shouldn't Miss This WeekendBetween benefit payments, filing deadlines, and ongoing CRA reviews, ...
06/06/2026

3 Tax Updates Canadians Shouldn't Miss This Weekend

Between benefit payments, filing deadlines, and ongoing CRA reviews, there are several developments Canadians should have on their radar this weekend.

1. Canada Groceries & Essentials Benefit

Over 12 million eligible Canadians are currently receiving a one-time GST/HST top-up of up to $717 as part of the rollout of the new Canada Groceries and Essentials Benefit. The first quarterly benefit payment is scheduled for July, with additional payments to follow in October, January, and April.

2. June 15 Filing Deadline Approaching

Self-employed individuals and their spouses or common-law partners have until June 15 to file their 2025 tax returns.

3. CRA Refund Delays Continue

If you're still waiting for a tax refund, you're not alone. Many taxpayers whose returns were selected for review are experiencing delays while the CRA requests additional documentation and verification.

Have questions about a CRA audit, reassessment, refund delay, or tax dispute?

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

📩 Email: [email protected]

Follow us for major tax updates in Canada.

Taxpage.com

All the tax help you need.

Can the CRA Estimate Your Income If It Doesn't Trust Your Records?Yes.When CRA auditors believe a taxpayer's books and r...
06/05/2026

Can the CRA Estimate Your Income If It Doesn't Trust Your Records?

Yes.

When CRA auditors believe a taxpayer's books and records are incomplete, unreliable, or missing, they may use alternative tax-assessment techniques to estimate income. These methods can rely on bank deposits, spending patterns, assets, liabilities, and lifestyle evidence rather than the income reported on a tax return.

The CRA commonly uses:

• The Bank Deposit Method
• The Projection (Markup) Method
• The Net-Worth Method

While these tools can be effective, they are not always accurate.

In some cases, loans, gifts, transfers between accounts, inheritances, gambling winnings, or other non-taxable amounts may be incorrectly treated as income, resulting in substantial tax assessments.

The good news?

Taxpayers can challenge these assessments by providing proper documentation, identifying non-taxable deposits, and exposing errors in the CRA's calculations.

If the CRA has reassessed you using one of these methods, don't assume the assessment is correct simply because it came from the CRA.

Learn more:
https://taxlawyer.com/how-to-beat-cra-alternative-tax-assessments-insights-from-a-canadian-tax-lawyer/

📞 Call 416-367-4222 for a FREE 10-minute consultation.
📩 Email: [[email protected]](mailto:[email protected])

Taxpage.com

All the tax help you need.

Today, we say goodbye (for now) to our 2025 articling student, Osinachi Obi-Njoku, on his final day at the firm.From day...
05/22/2026

Today, we say goodbye (for now) to our 2025 articling student, Osinachi Obi-Njoku, on his final day at the firm.

From day one, Osinachi brought energy, dedication, and thoughtful perspective to our team.

Reflecting on his experience at Rotfleisch & Samulovitch P.C., Osinachi shared:

“My articling experience at Taxpage has been excellent and highly rewarding. I was exposed to a wide range of tax matters, from GST/HST issues and CRA disputes to VDPs, tax planning, and litigation.

The highlight was working on a matter before the Tax Court of Canada; it taught me how critical the CRA stage is in shaping the strength of a court case.”

When asked what advice he would give incoming students, he noted:

“You must be willing to put in the work. Tax law is one of the most challenging areas of law, but Taxpage has a unique way of teaching an incredible amount within a short period.”

We thank Osinachi for his outstanding work and dedication over the past year and wish him every success as he begins his legal career.

Taxpage

All the tax help you need.

How We Resolved a Multi-Million Dollar Cross-Border Tax Dispute With the CRAWhat began as a routine CRA offshore audit i...
05/20/2026

How We Resolved a Multi-Million Dollar Cross-Border Tax Dispute With the CRA

What began as a routine CRA offshore audit in 2019 evolved into a seven-year cross-border tax dispute involving international information requests, Swiss banking issues, and complex offshore reporting considerations.

Our long-standing clients were initially under review for the 2010–2017 taxation years. At first, the audit proceeded through relatively standard channels. However, in 2021, the scope of the review expanded significantly beyond the original audit period.

During the process, previously closed offshore accounts and a Swiss trust connected to a non-resident family member were disclosed. Importantly, our position was that there was no Canadian tax exposure associated with those structures.

The matter escalated further when the CRA sought information from Swiss authorities based largely on signing authority and power of attorney concerns, despite the absence of beneficial ownership — a key legal distinction under Canadian tax law.

Given the cross-border implications, our team moved quickly and strategically.

We formally notified the Swiss bank that our clients held no beneficial ownership interest in the accounts in question and that no direct CRA request had been issued to them personally. At the same time, we coordinated with a leading Swiss tax law firm, advanced our legal position through the appropriate channels, and prepared for potential court proceedings in Canada if necessary.

Ultimately, the Swiss authorities declined the CRA’s request.

Although the international component was resolved, the domestic audit continued for several more years. Throughout the process, we maintained structured communication with the CRA, ensured ongoing compliance, and carefully managed the evolving audit strategy.

The Result:

After seven years, the CRA issued its final completion letter confirming:

• No reassessments

• No penalties

• No further action

Our clients were fully cleared.



Key Takeaways:

• Cross-border tax audits can evolve significantly over time

• International information-sharing requests must still comply with applicable legal standards and reporting requirements

• Proper documentation and early strategic representation matter enormously in offshore audits and disputes

• Taxpayers should maintain complete records for extended periods, particularly where international structures or assets are involved

Once a CRA audit begins, every communication and procedural step can carry significant consequences. Complex cross-border tax disputes should never be approached without experienced legal guidance.

Taxpage

All the tax help you need.

We are pleased to welcome our 2026 summer students: Jason Jin, Jessica Gan, and Maya Caplan.Jason recently completed his...
05/19/2026

We are pleased to welcome our 2026 summer students: Jason Jin, Jessica Gan, and Maya Caplan.

Jason recently completed his second year at Osgoode Hall Law School, where his growing interest in tax law was further shaped through research on the taxation of Decentralized Autonomous Organizations (DAOs).

Jessica is a Juris Doctor candidate at Osgoode Hall Law School with a focus on tax law, including the Income Tax Act, GST/HST, and tax treaties. She has also contributed to leading academic tax research initiatives and conferences.

Maya is pursuing her J.D. at Osgoode Hall Law School and continues to strengthen her advocacy and analytical skills through academic, practical, and moot court experience.

We are proud to have them join the team and look forward to supporting their professional development over the coming months.

Welcome to the team, and best wishes for a rewarding summer ahead.

From all of us at Rotfleisch & Samulovitch P.C.

Taxpage

All the tax help you need.

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