Bennett Jones on Tax Disputes: 
November 2025

Issue 39 of Bennett Jones on Tax Disputes, published on Taxnet Pro by Thomson Reuters, reviews key developments in Canadian tax litigation, court commentary and evolving administrative guidance. This issue features thought leadership and case analysis from members of Bennett Jones’ Tax group.

Anna Lekach reviews the Canada Revenue Agency’s new guidance on the Voluntary Disclosures Program, which expands eligibility and clarifies distinctions between “unprompted” and “prompted” applications. The updated framework offers increased access to relief and introduces new documentation requirements for domestic and international disclosures.

Antoine Messervier examines the Tax Court’s decision in Technology Venture Corporation v. The King, where a breach of settlement-offer confidentiality under Rule 147(3.8) resulted in the taxpayer incurring significant indemnity costs. substantial indemnity costs. He also summarizes the Auditor General of Canada’s 2025 Report on the CRA’s contact centres, highlighting concerns over long wait times, accuracy of information provided to taxpayers and the need for systemic service improvements.

Ed Kroft KC discusses proposed legislative changes to the Tax Court of Canada’s informal procedure monetary limits, encouraging input on how higher thresholds and related rule amendments could make dispute resolution more accessible and cost-effective for taxpayers.

This issue also provides an extensive Cases of Note section summarizing recent judgments on topics ranging from voluntary disclosure and penalties under section 162(7) to the application of the General Anti-Avoidance Rule, residence disputes and limits on appeals.

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