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Sophie Virji

Tax Lawyer at Bennett Jones Calgary

Partner

Anna Lekach

Associate

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

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

Jared A. Mackey

Corporate Tax Lawyer at Bennett Jones Calgary

Wade Ritchie

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

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

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

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

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Canadian Petroleum Tax Society, Fall Breakfast Series 2018

From the Same Authors