Thorsteinssons LLP

Canada’s Premier Tax Law Firm

Thorsteinssons LLP is Canada’s largest law firm practicing exclusively in taxation law. Our lawyers are consistently recognized as being among Canada’s leading tax practitioners.

Canadian Tax Law Blog

December 17, 2025

Favourable changes to the Voluntary Disclosures Program for non-compliant taxpayers

The Canada Revenue Agency (the “CRA”) administers the Voluntary Disclosures Program (“VDP”) to grant penalty and/or interest relief to taxpayers who voluntarily disclose errors or omissions in their past tax filings and pay the taxes owing, provided they meet the…

December 09, 2025

The cost of inadvertent settlement offer disclosure: Technology Venture Corporation v The King

Overview The Tax Court of Canada Rules (General Procedure) provide that a party may be entitled to substantial indemnity costs if the party makes a settlement offer and ends up obtaining an outcome at trial as favourable as or…

November 20, 2025

The taxpayer relief provisions: Accessing relief from penalties and interest

Overview Tax disputes generally hinge on whether the imposition of taxes and penalties is correct. However, there are situations where a taxpayer can be granted relief from the imposition of penalties and/or interest even if they were correctly levied. Subsection…

August 07, 2025

CRA publishes new policy document regarding information gathering powers

The Canada Revenue Agency (the “CRA”) is granted significant powers to gather information from persons under the Income Tax Act (Canada) (the “ITA”) and the Excise Tax Act (Canada) the (“ETA”), including the right to acquire and inspect documentation, enter…

July 10, 2025

Federal Court rejects CRA’s vague and inconsistent information request against Shopify Inc.

In the recent decision of Canada (National Revenue) v. Shopify Inc., 2025 FC 969 (“Shopify”), the Federal Court refused to authorize the Canada Revenue Agency (the “CRA”) to issue a so-called “unnamed person requirement” (“UPR”) to Shopify Inc. (the…

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Canadian Tax Law Blog

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