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Jehad Haymour

Tax Litigation Lawyer at Bennett Jones Calgary

Partner

Julia Qian Wang

Tax Lawyer at Bennett Jones Montreal

Anna Lekach

Tax Lawyer at Bennett Jones Calgary

Associate

Canada&rsquo;s updated transfer pricing rules, effective for tax years beginning after November 4, 2025, introduce a formal framework based on &ldquo;economically relevant characteristics,&rdquo; increasing scrutiny of cross-border intra-group transactions. Life sciences MNEs face heightened audit activity, including functional interviews and expanded information requests, making robust contemporaneous documentation and proactive audit readiness essential. Early engagement of transfer pricing and dispute specialists can help mitigate reassessment risk and ensure defensible positions.

Transfer Pricing Rules in Canada Considerations for the Life Sciences Industry

Considerations for the Life Sciences Industry

Transfer Pricing Rules in Canada

Sophie Virji

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

Edwin G. Kroft KC

Tax Litigation Lawyer at Bennett Jones

The 24th edition 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. Additionally, the publication features a report on the application of adverse inference in tax disputes.

Bennett Jones on Tax Disputes February 2023

Bennett Jones on Tax Disputes - February 2023

The 14th edition of Bennett Jones on Tax Disputes, published on <a rel="noopener noreferrer" href="https://www.gettaxnetpro.com/" target="_blank">Taxnet Pro</a> by Thomson Reuters, includes articles on (1) the impact of case law in the area of document disclosure related to policy relied upon by the Minister of National Revenue in raising an assessment pursuant to the general anti avoidance rule and (2) Rule 58 of the Tax Court of Canada Rules (General Procedure) and the pronouncements made by the Federal Court of Appeal in its recent decisions, including 632738 Alberta Ltd. v Canada 2021 FCA 43. The publication also has summaries of recent tax decisions, tables regarding tax appeals, the CRA business continuity plans and bulletins/practice directives from the courts.

Bennett Jones on Tax Disputes May 2021

Bennett Jones on Tax Disputes - May 2021

Ruth E. Promislow

Privacy, Cybersecurity & AI Lawyer

Stephen D. Burns

Energy & Infrastructure Technology Lawyer | IT/OT & Markets

Partner, Trademark Agent

J. Sébastien A. Gittens

Technology Lawyer & Trademark Agent

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

Robert W. Staley

Securities & Commercial Litigation Lawyer | Shareholder Disputes

Vice Chair and Partner

Doug Fenton

Litigation Lawyer at Bennett Jones Toronto

The Ontario Superior Court of Justice&rsquo;s decision in Nivora Group LLC v. Ping et al. clarifies the strict limits on Norwich orders in the context of crypto asset disputes. The Court dismissed a motion seeking third-party disclosure from cryptocurrency exchanges, reaffirming that Norwich relief is an extraordinary remedy available only where it is truly necessary and cannot be used to replace ordinary discovery. Even in cases involving alleged asset tracing, applicants must demonstrate that the third party is the only practicable source of the information and that the interests of justice favour disclosure.

Court Reaffirms Limits on Norwich Orders in Crypto Asset Disputes

The Ontario Court of Appeal's decision in Chanderpaul v. Caesars Convention Centre Ltd. clarifies when courts may pierce the corporate veil and hold shareholders personally liable for a corporation's wrongful conduct. While reaffirming the high threshold for veil-piercing claims, the decision provides important guidance on the types of conduct that may justify this exceptional remedy.

Ontario Court of Appeal Clarifies the Test for Piercing the Corporate Veil

Amanda C. McLachlan

Corporate & Regulatory Lawyer | Disputes, Investigations & Compliance

In Friel v. HUB International Limited, 2026 ONCA 313, the Ontario Court of Appeal upheld the enforceability of a forum selection clause designating the State of Delaware as the exclusive forum for resolving a dispute between a former employee in Ontario and his employer's Delaware-based parent entities over the exercise of vested share options. The decision provides important guidance for employers that structure equity incentive arrangements through related entities and reinforces the significance of clear contractual language delineating employment relationships from equity participation rights.

When Agreements Collide The Ontario Court of Appeal Upholds Forum Selection Provision in Friel v HUB

When Agreements Collide — The Ontario Court of Appeal Upholds Forum Selection Provision in Friel v. HUB

Andrew Young

Tax Lawyer at Bennett Jones Vancouver

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.

The Gwart Decision: The GAAR is not a Filler

From the Same Authors