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Edwin G. Kroft KC

Tax Litigation Lawyer at Bennett Jones

Partner

Antoine Messervier

Tax Lawyer at Bennett Jones Vancouver

Associate

Anna Lekach

Tax Lawyer at Bennett Jones Calgary

The November 2025 issue of Bennett Jones on Tax Disputes explores major developments in Canadian tax law, including new CRA guidance on the Voluntary Disclosures Program, court decisions on settlement confidentiality and costs, and proposed reforms to the Tax Court&rsquo;s informal procedure limits. The issue also features case summaries and insights from Bennett Jones&rsquo; tax litigators on emerging trends in tax dispute resolution.

Bennett Jones on Tax Disputes Issue 39

Bennett Jones on Tax Disputes: November 2025

Andrew Young

Tax Lawyer at Bennett Jones Toronto

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&rsquo; Tax group.

Bennett Jones on Tax Disputes Issue 38 September 2025

Bennett Jones on Tax Disputes: September 2025

Issue 37 of Bennett Jones on Tax Disputes, published on <a rel="noopener noreferrer" rel="noopener noreferrer" href="https://www.gettaxnetpro.com/" target="_blank">Taxnet Pro</a> by Thomson Reuters, features a review of notable tax cases, recent court guidance and ongoing appeal activity. This issue includes two articles from members of Bennett Jones’ Tax group.
<a rel="noopener noreferrer" rel="noopener noreferrer" href="https://bennettjones.com/youngandrew" target="_blank">Andrew Young</a> reviews the Seabridge decisions, focusing on the Canada Revenue Agency's (CRA's) challenges to Canadian exploration expense claims and the implications for investors in flow-through shares. 
<a rel="noopener noreferrer" rel="noopener noreferrer" href="https://bennettjones.com/messervierantoine" target="_blank">Antoine Messervier</a> discusses recent leave applications in tax matters before the Supreme Court of Canada, highlighting which were granted and which were denied.
Issue 37 also includes summaries of recent tax decisions, updated appeal tables and new bulletins and practice directives from the courts.

Bennett Jones on Tax Disputes June 2025

Bennett Jones on Tax Disputes: June 2025

Issue 36 of Bennett Jones on Tax Disputes, published on <a rel="noopener noreferrer" rel="noopener noreferrer" href="https://www.gettaxnetpro.com/" target="_blank">Taxnet Pro</a> 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. <a href="/People/K/Kroft-Ed">Ed Kroft KC</a> briefly asks whether the upcoming Federal Election of April 28, 2025 will impact tax dispute resolution and the administration and enforcement of tax legislation. <a href="/People/M/Messervier-Antoine">Antoine Messervier</a> 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.

Bennett Jones on Tax Disputes April 2025

Bennett Jones on Tax Disputes: April 2025

Hennadiy Kutsenko

New federal tax rules effective January 1, 2024 deny expense deductions for short-term rental properties that do not comply with provincial or municipal laws. The changes heighten enforcement risk by allowing the CRA to deny deductions indefinitely, in addition to existing penalties. This blog explains the new deduction denial rules, key exceptions and compliance considerations for short-term rental operators.

Comply or Lose Your Tax Deductions

Comply or Lose Your Tax Deductions: New Income Tax Act Rules Target Short-Term Rental Landlords

Drew C. Broughton

Corporate Commercial and M&A Lawyer at Bennett Jones Calgary

Jie (Kevin) Zhou

M&A, Private Equity and Corporate Lawyer at Bennett Jones Calgary

Jesse Fontaine

Commercial Transactions Lawyer at Bennett Jones Edmonton

The Ontario Court of Appeal confirmed that earn-out acceleration clauses are to be interpreted contextually, with materiality turning on a transaction&rsquo;s impact on the earn-out regime rather than its size or value. The decision reinforces the exceptional nature of earn-out acceleration remedies and the importance of precise drafting in share purchase agreements.

ONCA Affirms Denial of Claim for Earn Out Acceleration

ONCA Affirms Denial of Claim for Earn-Out Acceleration

Curtis A. Cusinato

Cross-border Mergers and Acquisitions and Capital Markets Lawyer at Bennett Jones Toronto

Vice Chair and Partner

Bronwynn Shaw

Corporate Commercial Lawyer at Bennett Jones Toronto

Kristopher R. Hanc

M&A and Capital Markets Lawyer at Bennett Jones Toronto

After a year marked by headline-making large-cap transactions, Canada&rsquo;s M&amp;A market enters 2026 with measured confidence. This update analyzes the data behind recent deal activity, explores the evolving role of infrastructure, private capital and credit markets and highlights the risks and opportunities shaping the year ahead.

Canadas Q4 2025 M and A Landscape

Measured Confidence in Canada's M&A Landscape in 2026

Canada's Q4 2025 M&A Landscape

J. Sébastien A. Gittens

Intellectual Property and Technology Commercialization Lawyer at Bennett Jones Calgary

Partner, Trademark Agent

Stephen D. Burns

Technology Lawyer, Intellectual Property Lawyer at Bennett Jones Calgary

Ahmed Elmallah

Intellectual Property Lawyer at Bennett Jones Edmonton

Counsel, Patent Agent, Trademark Agent

Shadow AI is increasingly present in workplaces as employees adopt unauthorized AI tools to improve efficiency, often without organizational oversight. While these tools may offer short-term productivity gains, they create significant compliance, governance, privacy and liability risks. This post examines the drivers of shadow AI, the risks it poses and practical strategies organizations can implement to manage and mitigate those risks.

Hiding in the Shadows The Perils of Shadow AI on Your Organization

Hiding in the Shadows: The Perils of Shadow AI on Your Organization  

Denise D. Bright

Public and Private Company Financial Transactions and Securities Lawyer at Bennett Jones Calgary

Partner 

Keely Cameron

Litigation Lawyer at Bennett Jones Calgary

Chyna Brown

Commercial Litigation Lawyer at Bennett Jones Calgary 

In Royal Bank of Canada v Patterson Dental Canada Inc, the Alberta Court of Appeal clarified how PPSA priority rules apply where assets used in a corporate business are personally owned by a director. The Court confirmed that ownership and registration against the correct debtor are decisive in priority disputes, and provided guidance on the treatment of leases and the proper distribution of holdbacks in insolvency sales.

Some Recent Developments and Trends in Canadian Income Tax Dispute Resolution

From the Same Authors