People

Services

Industries

Firm

About

Knowledge

Careers

News

Events

Contact

Connect

Privacy Policy

Disclaimer

Terms of Use

Accessibility

Payments

Legal

Calgary

Toronto

Edmonton

Ottawa

Vancouver

New York

Montréal

Edwin G. Kroft KC

Tax Litigation Lawyer at Bennett Jones

Partner

Andrew Young

Tax Lawyer at Bennett Jones Vancouver

Associate

The June 2026 issue of Bennett Jones on Tax Disputes provides insight into recent tax litigation developments, including the Tax Court's decision in 941624 Alberta Ltd. v. The King on the large corporation objection rules, updates from the Taxpayers' Ombudsperson, and summaries of recent tax decisions and appeal activity.

Bennett Jones on Tax Disputes Issue 42

Bennett Jones on Tax Disputes: June 2026

Sophie Virji

Tax Lawyer at Bennett Jones Calgary

Anna Lekach

The Tax Court of Canada&rsquo;s decision in ExxonMobil Canada Resources Company v. The King highlights the risks of imprecise language in internal corporate communications during CRA audits. The case demonstrates how seemingly innocuous statements can be misconstrued and relied upon to support reassessment positions. It underscores the importance of careful, deliberate drafting to mitigate audit risk and avoid unintended interpretations.

The Issue with Misconstrued Internal Statements

Learnings from ExxonMobil Canada Resources Company v. The King

Mackenzie Thomas

Lawyer at Bennett Jones Toronto

Issue 41 of Bennett Jones on Tax Disputes examines recent developments in Canadian tax litigation, with a focus on jurisdictional limits, procedural compliance, and case management in the Tax Court of Canada. Featuring commentary from members of the Bennett Jones Tax group, this edition analyzes key decisions including MEGlobal, Culig, and Opheim, and provides practical guidance for taxpayers and advisors navigating tax disputes.

Bennett Jones on Tax Disputes Issue 41

Bennett Jones on Tax Disputes: March 2026

Jehad Haymour

Tax Litigation Lawyer at Bennett Jones Calgary

The Tax Court of Canada allowed ExxonMobil Canada Resources Company&rsquo;s appeal in a significant transfer pricing dispute concerning the deductibility of feasibility study costs related to a proposed Alaska-to-North America natural gas pipeline project. The Court found that the costs were incurred for the purpose of earning income and rejected the Minister&rsquo;s transfer pricing adjustments and Part XIII tax assessment. The decision provides important guidance on transfer pricing analysis, the application of the OECD Guidelines and the evidentiary role of expert testimony in tax disputes.

ExxonMobil Wins in Tax Court in Transfer Pricing Dispute

Curtis A. Cusinato

Cross-border Mergers and Acquisitions and Capital Markets Lawyer

Co-Head of Mergers & Acquisitions Services

Tyler B. McAuley

Corporate Lawyer at Bennett Jones Toronto

Kevin Myson

Energy & Corporate Lawyer | M&A, Natural Resources & Transport

Canada&rsquo;s M&amp;A market remained resilient through the first half of 2026, with deal activity increasingly concentrated in large, strategically important transactions despite ongoing economic and geopolitical uncertainty. This quarterly update explores the sectors driving Canadian M&amp;A, including energy, digital infrastructure and real estate, and examines how policy developments, AI-related demand and shifting investment priorities are shaping dealmaking trends. It also highlights key opportunities and considerations for investors as activity is expected to accelerate in the second half of the year.

Canadas Q2 2026 MA Landscape

Sustained Momentum Driven by Energy Investment and AI-Related Demand

Canada's Q2 2026 M&A Landscape

Jessica Kennedy

Regulatory Lawyer at Bennett Jones Calgary

Martin Ignasiak KC

Energy & Industrial Projects Lawyer

Head of Energy Regulatory Services

Larissa D. Lees

On June 9, 2026, the Government of Alberta enacted the Data Centre Regulation, AR 117/2026 under the Electric Utilities Act, codifying the province&rsquo;s &ldquo;bring your own generation&rdquo; policy and providing the legal foundation for the Alberta Electric System Operator&rsquo;s grid connection process for large data centres.&nbsp;

Albertas BYOG Framework

Alberta's BYOG Framework: What Data Centre and Generation Proponents Need to Know

J. Sébastien A. Gittens

Technology Lawyer & Trademark Agent

Partner, Trademark Agent

Caroline Poirier

IT, Privacy & Data Protection Lawyer

Stephen D. Burns

Energy & Infrastructure Technology Lawyer | IT/OT & Markets

Earlier this month, the federal government introduced the proposed federal Protecting Privacy and Consumer Data Act (PPCDA) &ndash; a signal that Canada&rsquo;s private-sector privacy landscape may undergo significant transformation imminently. To assist organizations that conduct business in Canada with their potential compliance efforts with respect thereto, the following is intended to provide a non-exhaustive, high-level comparison between: (i) the PPCDA; (ii) Canada's Personal Information Protection and Electronic Documents Act (PIPEDA); (iii) Qu&eacute;bec&rsquo;s Act respecting the protection of personal information in the private sector (the Qu&eacute;bec Privacy Act, as amended by Law 25); and (iv) the Personal Information Protection Acts of Alberta and British Columbia (collectively, the PIPAs).

A Comparison of the PPCDA PIPEDA Quebecs Privacy Act and PIPA

A Comparison of the PPCDA, PIPEDA, Quebec's Privacy Act and PIPA

Adam W. Taylor

Corporate Commercial Lawyer at Bennett Jones Toronto

Matthew Flynn

Technology Transaction Lawyer at Bennett Jones Toronto

Simon Grant

Financial Services & Regulatory Lawyer

Partner 

Canada's proposed Consumer-Driven Banking Regulations provide the first detailed framework for implementing the country's open banking regime, setting out requirements for accreditation, security, consent, data sharing and ongoing compliance. The proposed regulations also highlight the growing connection between consumer-driven banking and privacy reform, particularly as Canada advances broader data mobility rights. Organizations should assess the potential impact of the framework and consider participating in the current consultation process. 
<div>&nbsp;</div>

Canada Advances Consumer Driven Banking Framework with Proposed Regulations

Canada Advances Consumer-Driven Banking Framework with Proposed Regulations

Ruth E. Promislow

Privacy, Cybersecurity & AI Lawyer

On June 4th, 2026, the federal government released Canada&rsquo;s National Artificial Intelligence Strategy: AI for All (the Strategy). The Strategy aims to ensure that artificial intelligence serves Canadians, strengthens businesses and communities and enhances Canada&rsquo;s control over its technological future through six key pillars.

Canadas AI for All Strategy Building Trust Innovation and Sovereignty in the Era of AI

Canada’s AI for All Strategy: Building Trust, Innovation and Sovereignty in the Era of AI

Title Alphabetical

Title

normal

Bennett Jones on Tax Disputes - June 2019

From the Same Authors