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Tax Litigation & Dispute Resolution

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  • Key Contacts
  • Recent Recognition
  • Insights, News & Events
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  • Recent Recognition
  • Insights, News & Events

Based upon our experience in resolving and mitigating the risks of Canadian tax disputes, we provide clear and cost-effective paths to success for our clients.

Tax disputes have increasingly become a way of life for taxpayers both in Canada and beyond. In the face of intense media scrutiny relating to tax avoidance and tax evasion, the Canadian government has provided CRA with additional resources to expand CRA audits of Canadian taxpayers, to focus on cross-border transactions and to target specific types of arrangements that CRA considers offensive. Taxpayers face the ongoing challenge of defending tax positions and managing tax risk in the face of a constantly changing legislative, administrative and judicial landscape.

Bennett Jones lawyers are well positioned to provide strategic advice and support to clients in avoiding tax disputes, managing tax disputes when they arise, resolving tax disputes prior to litigation and, if necessary, litigating the disputes through the courts. We work with our clients to resolve tax disputes efficiently and effectively. Our lawyers represent clients in the Tax Court of Canada, the Federal Court, the Federal Court of Appeal, provincial courts, the Supreme Court of Canada and in dealings with CRA, including Canadian Competent Authority.

What Clients Say

“Top marks… experts in both Canadian and international law, and their advice and strategy is above grade." Chambers Global, Tax

Bennett Jones was founded in 1922 and has been providing Canadian tax advice to clients for decades. Members of our Tax Litigation and Disputes Resolution Group collectively offer over 150 years of experience to clients. Bennet Jones has more individuals ranked in Chambers Global with respect to Tax Litigation than any other law firm in Canada. Former Supreme Court of Canada Justice, the Honorable John C. (Jack) Major CC, QC, is Counsel to the firm and Bennett Jones lawyers have been appointed as judges of the Tax Court of Canada, the Federal Court and the Federal Court of Appeal. Ed Kroft, Q.C., has served on the Tax Court of Canada Rules Committee and the Federal Court Bench and Bar Committee. We publish Bennett Jones on Tax Disputes through Thomson Reuters and TaxNetPro.

The Bennett Jones Tax Litigation & Dispute Resolution team advises clients on tax disputes relating to issues such as the following:

  • Federal and provincial GAAR and other tax avoidance provisions;
  • Goods & Services Tax and Harmonized Sale Tax;
  • Excise Tax;
  • Transfer pricing and advance pricing arrangements;
  • Income tax treaty interpretation and competent authority requests;
  • Foreign accrual property income;
  • Financial transactions;
  • Valuation of business assets;
  • Characterization of amounts as income or capital gains;
  • SR&ED tax credits;
  • Shareholder and employee benefits;
  • Provincial capital taxes.

Cases Representative of Our Lawyers' Experience

  • Canada v. CBS Canada Holdings Co., 2020 FCA 4
  • The Mark Anthony Group Inc. v. The Queen, 2019 FCA 183
  • CBS Canada Holdings Co. v. The Queen, 2018 TCC 188
  • CIT Group Securities (Canada) Inc. v. The Queen, 2016 TCC 163 and 2017 TCC 86
  • Canada v. Repsol Canada Ltd., 2017 FCA 193
  • Transalta Corporation v. The Queen, 2012 FCA 20
  • Canada v. Global Equity Fund Ltd., 2012 FCA 272
  • Theratechnologies Inc. v. Minister of National Revenue, 2012 FC 1376
  • HSBC Bank Canada v. The Queen, 2011 TCC 37, 2010 TCC 462 and 20110 TCC 228
  • Husky Oil Ltd. v. The Queen, 2010 FCA 125
  • Lipson v. The Queen, 2007 FCA 113 and 2009 SCC 1
  • The Queen v. McLarty, 2008 SCC 26
  • MacKay v. The Queen, 2007 TCC 94 and 2008 FCA 105
  • Univar Canada Ltd. v. The Queen, 2005 TCC 723

Key Contacts

  • Jehad  Haymour Jehad Haymour, Partner
  • Edwin G. Kroft Q.C. Edwin G. Kroft Q.C., Partner
  • Martin A.U. Sorensen Martin A.U. Sorensen, Partner
  • Deborah  Toaze Deborah Toaze, Partner
  • Related Lawyers

Recent Recognition

Chambers Canada
Ranked, Tax
Chambers Global: The World's Leading Lawyers for Business
Ranked Dispute Resolution
Ranked, Tax
The Canadian Legal Lexpert Directory
Most Frequently Recommended, Corporate Tax, Calgary
Consistently Recommended, Corporate Tax, Toronto
The Legal 500 Canada
Recommended, Tier 1, Dispute Resolution - Alberta
Recommended, Dispute Resolution - Ontario
Recommended, Tax
World Tax
Ranked, Tax Controversy

Insights, News & Events

Announcements

Bennett Jones in Chambers Global 2021

February 22, 2021
       

Articles

Bennett Jones on Tax Disputes - January 2021

January 14, 2021
       

Announcements

Twenty-Five Bennett Jones Lawyers in Lexpert/ALM 500 Directory

December 17, 2020
       

Announcements

Bennett Jones: Tier 1 Practices and Leading Lawyers in Legal 500

November 19, 2020
       

Articles

Bennett Jones on Tax Disputes - November 2020

November 02, 2020
       

Articles

Bennett Jones on Tax Disputes - September 2020

September 03, 2020
       

Articles

Canadian Accountant on Me Too Defeats You Too in Tax Court

August 26, 2020
       

Blog

Me Too Defeats You Too in Tax Court

August 24, 2020
       

Articles

Bennett Jones on Tax Disputes - August 2020

July 31, 2020
       

Blog

Space Travel and Taxes: A Cautionary Tale of Shareholder Benefits

July 27, 2020
       

Articles

Bennett Jones on Tax Disputes - June 2020

June 24, 2020
       

Speaking Engagements

Ed Kroft on Tax Dispute Resolution During the Pandemic

June 23, 2020
       

Articles

Tax Planning Strategies in a Market Downturn: Loss

June 19, 2020
       

Articles

Tax Planning Strategies in a Market Downturn: Trusts

June 12, 2020
       

Blog

Tax Court of Canada Update

June 08, 2020
       

Articles

Tax Planning Strategies in the Market Downturn: Estate Freezes, Income Splitting

June 04, 2020
       

Articles

Bennett Jones on Tax Disputes - May 2020

May 26, 2020
       

Blog

The Reopening of the Tax Court of Canada: Timeline and Protocols as at May 15, 2020

May 19, 2020
       

Blog

Are You Liable For Another Person’s Unpaid Federal or Provincial Taxes?

April 17, 2020
       

Blog

Suspension of Limitations Periods in British Columbia in Response to COVID-19

March 28, 2020
       

Blog

Ontario Suspends Limitation Periods and Litigation Time Limits During COVID-19 Crisis

March 24, 2020
       

Blog

Modified Deadlines for Federal Tax Litigation Proceedings

March 23, 2020
       

Articles

Federal Court of Appeal: Inducement Taxable as Restrictive Covenant Payment

March 04, 2020
       

Blog

FCA Confirms that an Inducement is Taxable as a Restrictive Covenant Payment

February 04, 2020
       

Articles

The Dawn of a New Day: The Preliminary Ruling Docket (Tax Court of Canada)

January 2020
       

Announcements

Twenty-three Bennett Jones Lawyers in Leading 500 in Canada

December 13, 2019
       

Announcements

Bennett Jones: Canada’s Leading Litigation Lawyers

November 29, 2019
       

Announcements

Bennett Jones is Top-Tier in The Legal 500

November 18, 2019
       

Articles

Bennett Jones on Tax Disputes November 2019

November 2019
       

Announcements

Bennett Jones' Women in Tax Leaders 2020

October 01, 2019
       

Announcements

Bennett Jones' World Tax Leaders 2020

October 01, 2019
       

Announcements

Bennett Jones' World Transfer Pricing Leaders 2020

October 01, 2019
       

Blog

Whistleblowing Pays Off—New CRA Data on First Payments to Informants

August 21, 2019
       

Articles

Bennett Jones on Tax Disputes - August 2019

August 14, 2019
       

Articles

Bennett Jones on Tax Disputes - June 2019

June 17, 2019
       

Blog

Bennett Jones Speaks before Senate Committee on Tax Issues for Energy Investments

May 30, 2019
       

Speaking Engagements

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

May 27, 2019
       

Articles

Bennett Jones on Tax Disputes

April 10, 2019
       

Updates

Orders for Consolidation and Common Hearings Under Tax Court Rule 26

January 04, 2019
       

Articles

Large Corporation Objection and Appeal Process: What’s Wrong with This Picture"

2018
       

Blog

No Deemed Trust for Unremitted GST and HST Post-Bankruptcy

November 13, 2018
       

Updates

Property Tax Priorities in Alberta Insolvency Proceedings: Current Uncertainty

November 12, 2018
       

In the News

Martin Sorensen in National Post on Tax Audits Gone Bad

September 06, 2018
       

Blog

Implication of Daishowa to Purchasers

January 19, 2018
       

Articles

Canadian Tax Focus

2018
       

Blog

Amendments to Alberta's Municipal Government Act Likely to Reduce Time and Cost of Property Tax Review Process

January 23, 2017
       

Articles

2016 Tax Conference Report

2017
       

Speaking Engagements

Canadian Tax Foundation Annual Conference 2017

2017
       

Blog

SCC Confirms General Intention not Sufficient for Rectification in Tax Cases

December 09, 2016
       

Updates

The Latest Word on Subsequent Legislative History and the GAAR

November 01, 2016
       

Articles

Some Trends and Developments in Canadian Tax Controversy and Jurisprudence

July 2016
       

Speaking Engagements

Tax Dispute Resolution 1

May 29 - June 3, 2016
       

Speaking Engagements

Some Recent Developments and Trends in Canadian Income Tax Dispute Resolution

May 1-4, 2016
       

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