Davidow & Nelson Blog

Deductible?: Commissioned Employee Clothing Purchases

A July 30, 2025 Tax Court of Canada case considered whether luxury clothing expenses claimed by a commissioned employee for the 2016 to 2018 taxation years were deductible against the individual’s employment income. The taxpayer worked as a sales associate for Holt Renfrew and argued that she was required, either expressly or implicitly, to incur… Read more »

Caution!: Electronic Correspondence With CRA

An April 29, 2025 French Federal Court case reviewed the taxpayer’s application for judicial review of CRA's denial of a waiver of interest and penalty taxes on her excess TFSA contributions for the 2021 and 2022 taxation years (1%/month during which the excess contributions remained in the TFSA). On July 26, 2022, CRA issued a… Read more »

Decline in Value: TFSA Excess Contributions

A July 25, 2025 Federal Court case found that CRA s denial of penalty tax relief on excess TFSA contributions was reasonable. Due to the loss of value in the taxpayer’s TFSA, the taxpayer could not withdraw the full amount of his excess contribution. The taxpayer noted that without relief, his only means of reducing… Read more »

Action Needed: Automatic Change to Electronic Mail for Businesses

As of June 16, 2025, CRA changed the default correspondence method for most businesses to online only (i.e. not delivered by paper mail). As business correspondence is presumed received on the date that it is posted online to CRA’s My Business Account, it can be problematic if correspondence requiring action goes unnoticed. To receive notifications… Read more »

Changes to the Program: Voluntary Disclosures

The voluntary disclosures program (VDP) provides taxpayers with a chance to correct past tax errors or omissions before CRA finds them. If CRA accepts a disclosure, taxpayers may receive some penalty and interest relief and will not be referred for criminal prosecution. Any taxes owing will still have to be paid by the taxpayer in… Read more »

Tax Tidbits

Some quick points to consider…  Income tax refunds and other federal benefits can be applied to outstanding CEBA (Canada Emergency Business Account) loans without the taxpayer’s approval or direction. CRA publishes the current estimated wait times on their phone lines on the Contact the CRA webpage (https://www.canada.ca/en/revenue-agency/corporate/contact-information.html). Online platforms that facilitate activities such as short-term… Read more »

Potential Tax-Related Changes: Liberal Election Platform

With the most recent federal election resulting in a Liberal minority government, individuals and businesses should be aware of their tax-related platform proposals, as summarized in the listing below. Many are broad and lack detail, and some were previously announced by the former government. Business items included: – reintroducing the multi-unit rental building (MURB) tax… Read more »

Personal Liability: De Facto Director

A director of a corporation, non-profit organization or other entity can be personally liable for payroll source deductions and GST/HST that the entity fails to remit to CRA, unless the director exercised due diligence to prevent failure to remit these amounts on a timely basis. An individual can be held personally liable for up to… Read more »

Taxpayer Relief: GST/HST Registration and Remittance

A December 20, 2024 Federal Court case reviewed an application for judicial review of CRA’s decision denying penalty and interest relief related to the taxpayer’s failure to register for GST/HST and file GST/HST returns for the 2020 through 2022 years. CRA notified the taxpayer on June 23, 2023 that he was required to register for… Read more »