Article

Bennett Jones on Tax Disputes : 
September 2025

October 1, 2025
Authors
Edwin G. Kroft KCPartner
Antoine MesservierAssociate
Andrew YoungAssociate

Issue 38 of Bennett Jones on Tax Disputes, published on Taxnet Pro by Thomson Reuters, features a review of notable tax cases, recent court guidance and ongoing appeal activity. This issue includes several articles from members of Bennett Jones’ Tax group.

Andrew Young reviews draft legislation that would significantly extend the CRA’s (Canadian Revenue Agency) audit powers, including the ability to compel answers under oath, impose daily penalties, and issue notices of non-compliance.

Ed Kroft K.C. provides commentary on the CRA’s updated guidance on the mandatory disclosure rules, and with Antoine Messervier, discusses the CRA’s transition to online delivery of business correspondence and its risks for taxpayers and advisors.

Antoine also reviews the Taxpayers’ Ombudsperson’s 2024–2025 Annual Report, which highlights the top five taxpayer complaint trends and offers key recommendations to improve CRA services.

This issue further covers judicial commentary on Crown conduct in the Tax Court of Canada, along with case summaries and appeal updates from across the courts.

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

Work With Our Tax Litigation & Dispute Resolution group

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 Amrita Kochhar at kochhara@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.

Authors

Edwin G. Kroft KC, Partner  •   Chair, Tax Litigation and Dispute Resolution Practice
Vancouver, Toronto  •   604.891.5335  •   krofte@bennettjones.com
Antoine Messervier, Associate
Vancouver  •   (604) 891-5396  •   messerviera@bennettjones.com
Andrew Young, Associate
Toronto  •   416.777.7860  •   youngan@bennettjones.com