Last blog added on Monday, September 22nd, 2025

Information About Rosen Tax Law Blog

Recent Posts

Below is a preview of the five most recent posts from the blog Rosen Tax Law Blog. To read these posts in their entirely or subscribe to future updates from this blog, please visit their website!

  • Missing Deadlines in Tax Disputes: Why Procedure Still Matters

    Background and Procedural History A recent decision from the Federal Court of Appeal serves as a strong reminder that, in tax disputes, procedure can be just as important as substance. Even where a taxpayer raises constitutional and/or Indigenous rights, failing to follow the required steps under th … Read more »

  • Reopening Statute-Barred Tax Years: Lessons from Marleau v. The King

    Overview of the Decision The recent Tax Court of Canada decision in Marleau v. The King explains when the Canada Revenue Agency (“CRAâ€�) can go back and reassess taxes from years that are normally considered “closed.â€� For most taxpayers, once enough time has passed after filing a return, it i … Read more »

  • Bare Trusts in Real Estate: When to Use Them and How They Affect Taxation

    Bare trusts can be a useful tool in real estate transactions for privacy and tax neutrality, yet they are often misunderstood or overlooked. Like all tax planning tools, bare trusts come with compliance obligations that property owners should be aware of, especially, in light of recent changes to ba … Read more »

  • Understanding Requirements to Pay

    Being on the receiving end of legal action from the Canada Revenue Agency (“CRAâ€�) can be incredibly stressful. Taxpayers who receive a “Requirement To Payâ€� are often already aware of an outstanding tax liability and may have received prior correspondence or collection calls from the CRA. At … Read more »

  • Navigating Properties with CRA Liens: What Sellers Need to Know

    Selling a property already comes with many stresses and complexities, but when the CRA places a lien on the property, those complexities increase. Whether you’re a homeowner or investor, understanding how CRA liens affect real estate transactions is essential to avoiding costly delays or surprises … Read more »