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Research & Publications

SHAPING THE future.

Beyond practice — researching and writing on the evolution of Canadian tax law.

Current Research

Canadian Tax Reform

Schulich School of Law, Dalhousie University
Master of Laws (LLM)
In progress — Expected completion 2027

Investigating how Canadian income tax legislation can evolve to better serve taxpayers, practitioners, and the public interest. This research examines the structural foundations of the Income Tax Act and proposes frameworks for meaningful reform.

Publications
CRA Audit/Assessment Practices 2022
Co-authored with Andrew Plant · Atlantic Provinces Tax Conference, 2022, 9:1-35
Examines CRA audit procedures, Requirements for Information, and solicitor-client privilege for accountant work.
Wellness Expenses and Medical Expense Tax Credit
Tax Hyperion, Vol. 19, Issue 5, September–October 2022
Three-part publication on leveraging the non-refundable medical expense tax credit under s.118.2 for wellness therapies.
Filing a Joint Election for Spousal Rollover due to Marriage Breakdown
Tax Hyperion, Vol. 18, Issue 5, September–October 2021
Examines deeming rules and available exceptions including joint election for spousal rollover relief.
A Special Rule For A Specific Instance — Connected And Control
Tax Hyperion, Vol. 18, Issue 4, July–August 2021
Examines subsection 186(7) of the Income Tax Act regarding how “connected” should be interpreted.
Intercorporate Shareholdings and 110.6(15)(b) — Are You Offside?
Tax Hyperion, Vol. 18, Issue 2, March–April 2021
Planning considerations for QSBCS definitions and Lifetime Capital Gains Exemption access.
Would a ‘Book of Business’ Make a Business?
Tax Hyperion, Vol. 18, Issue 1, January–February 2021
Examines how a client list functions as a critical asset for service-based sole proprietors.
Employer Support for Employee Movement Within Canada
Tax Hyperion, Vol. 17, Issue 6, November–December 2020
Addresses employer handling of employee relocations and the three approaches to moving expenses.
The Redesigned Canada Emergency Wage Subsidy Program
Tax Hyperion, Vol. 17, Issue 4, July–August 2020
Examines Bill C-20 modifications to CEWS program revenue decline requirements.
The Client, Accountant and Lawyer: A Necessary Relationship
Tax Hyperion, Vol. 16, Issue 5, September–October 2019
Examines solicitor-client privilege for communications among lawyers, accountants, and clients in tax planning.
Conferences & Speaking
Active participant in the Canadian tax community.
Canadian Tax Foundation — Annual Conference
Canadian Tax Foundation — Pacific Regional Conference (Vancouver)
Canadian Tax Foundation — Ontario Regional Conference (Toronto)
Canadian Tax Foundation — Atlantic Regional Conference

Conference photos and speaking engagements updated annually.

Topics of Interest
General Anti-Avoidance Rule (GAAR) Alternative Minimum Tax Expanded CRA Audit Powers Mandatory Disclosure Rules Trust Reporting Requirements Intergenerational Business Transfers

Want to discuss the research?

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hello@primrosetax.ca +1 (902) 510-0430