Canada: Tax Authorities

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Why Ontario Employer Health Tax (EHT) Assessment Disputes Frequently Escalate Into Tax Litigation: EHT Rules, Tax Audit Risk, And EHT Appeals
Employer Health Tax Ontario (EHT) is a critical provincial payroll tax that continues to generate significant tax audit disputes and litigation risk for Ontario employers. As businesses grow, restructure, or adopt more complex payroll and corporate arrangements, exposure to an Employer Health Tax reassessment increases materially.
Canada Tax
RS
Rotfleisch & Samulovitch P.C.
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Gill V. The King -Transferring Property Among Family Members, When You’re In Debt To CRA? That Triggers Secondary Tax Liability (Because It Appears To Be A Tax Dodge)
Section 160 of the Income Tax Act (ITA) is one of the most potent collection tools available to the Canada Revenue Agency (CRA). While most tax liabilities are personal to the individual who earned the income, section 160 creates a form of “derivative” or secondary liability.
Canada Tax
RS
Rotfleisch & Samulovitch P.C.
Curated
Federal Court Of Appeal Strikes Down CCPC Continuance Planning Under GAAR In Canada V. DAC Investment Holdings Inc: Guidance From Canadian Tax Lawyer
On February 20, 2026, the Federal Court of Appeal (FCA) released its decision in Canada v. DAC Investment Holdings Inc. (DAC), 2026 FCA 35, overturning the Tax Court of Canada’s (TCC) ruling that a corporate continuance used to exit the Canadian-controlled private corporation (CCPC) regime did not amount to abusive tax avoidance.
Canada Tax
RS
Rotfleisch & Samulovitch P.C.
Curated
Federal Court Of Appeal Strikes Down CCPC Continuance Planning Under GAAR In Canada V. DAC Investment Holdings Inc: Guidance From Canadian Tax Lawyer
On February 20, 2026, the Federal Court of Appeal (FCA) released its decision in Canada v. DAC Investment Holdings Inc. (DAC), 2026 FCA 35, overturning the Tax Court of Canada’s (TCC) ruling that a corporate continuance used to exit the Canadian-controlled private corporation (CCPC) regime did not amount to abusive tax avoidance.
Canada Tax
RS
Rotfleisch & Samulovitch P.C.
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