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Bennett Jones on Tax Disputes: April 2025

April 4, 2025
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Issue 36 of Bennett Jones on Tax Disputes, published on Taxnet Pro by Thomson Reuters, features an overview of recent cases of note and cases under appeal. This issue contains three articles from members of Bennett Jones' tax group. Ed Kroft KC briefly asks whether the upcoming Federal Election of April 28, 2025 will impact tax dispute resolution and the administration and enforcement of tax legislation. Antoine Messervier reviews the recent Uppal Estate decision in which the Tax Court struck assumptions of fact pleaded in the alternative and additional penalties from the Crown's Reply. Antoine also analyzes the UKSC's decision in Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs and its impact on the interpretation of the Canada-UK tax treaty.

If you have any questions about the cases in this edition of Bennett Jones on Tax Disputes, please reach out to Ed Kroft KC, Chair of the Bennett Jones Tax Litigation and Dispute Resolution group.

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Our team is well-positioned to provide strategic advice and support to clients in avoiding tax disputes, managing tax disputes when they arise, resolving tax disputes prior to litigation and, if necessary, litigating the disputes through the courts. We work with our clients to resolve tax disputes efficiently and effectively. Our lawyers represent clients in the Tax Court of Canada, the Federal Court, the Federal Court of Appeal, provincial courts, the Supreme Court of Canada and in dealings with CRA.

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For permission to republish this or any other publication, contact Bryan Canning at canningb@bennettjones.com.

For informational purposes only

This publication provides an overview of legal trends and updates for informational purposes only. For personalized legal advice, please contact the authors.

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