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Jared A. Mackey

Corporate Tax Lawyer at Bennett Jones Calgary

Partner

Wade Ritchie

Tax Lawyer at Bennett Jones Calgary

Associate

Sophie Virji

The <a href="https://www.budget.canada.ca/2023/home-accueil-en.html">2023 Canadian Federal Budget</a>, released March 28, 2023 (Budget 2023), proposes significant amendments to expand the application of Canada's general anti-avoidance rule. The government has invited the public to submit written comments on the proposed amendments by May 31, 2023.

Budget 2023 Proposes Significant Amendments to Canadas General Anti Avoidance Rule

Budget 2023 Proposes Significant Amendments to Canada's General Anti-Avoidance Rule

Edwin G. Kroft KC

Tax Litigation Lawyer at Bennett Jones

Jehad Haymour

Tax Litigation Lawyer at Bennett Jones Calgary

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

The Minister of National Revenue issued an order on August 31, 2020. This is the first order issued under the Time Limits and Other Periods Act (COVID-19) (TLOPA). The August 31 Order extends the time limit to reassess taxpayers and certain filing deadlines under the Income Tax Act (Canada) (ITA) and under the Excise Tax Act (ETA).

Rules of Reassessment The First Order is Issued Under the Time Limits and Other Periods Act COVID

Rules of Reassessment: First Order Issued Under the Time Limits and Other Periods Act (COVID-19) 

On July 27, 2020, the Time Limits and Other Periods Act (COVID-19) (TLOPA), respecting timelines under the Income Tax Act (ITA) and the Tax Court of Canada Act (TCCA), came into force when Bill C-20 received Royal Asset. The legislation has not changed since it was first introduced on June 10, 2020, as part of Bill C-17.

Limitation Periods for Tax Disputes Might Now Be Extended

Hennadiy Kutsenko

Tax Lawyer at Bennett Jones Toronto

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.

Anatomy of a Tax Dispute Understanding the CRA Audit and Objection Process

From the Same Authors