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Edwin G. Kroft KC

Tax Litigation Lawyer at Bennett Jones

Partner

Andrew Young

Tax Lawyer at Bennett Jones Vancouver

Associate

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.

Bennett Jones on Tax Disputes Issue 42

Bennett Jones on Tax Disputes: June 2026

Jehad Haymour

Tax Litigation Lawyer at Bennett Jones Calgary

Julia Qian Wang

Tax Lawyer at Bennett Jones Montreal

Anna Lekach

Tax Lawyer at Bennett Jones Calgary

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

Anu Nijhawan KC

M&A, Corporate Financing and International Tax Lawyer

Lead Director and Head of Tax Department

Hennadiy Kutsenko

Tax Lawyer at Bennett Jones Toronto

Counsel

Talia K. Bregman

Management-side Employment Lawyer

Employment Services, National Practice Group Leader

Recent guidance from the Organisation for Economic Co-operation and Development provides important clarity on when cross-border remote work arrangements may give rise to a permanent establishment under international tax treaties. The analysis focuses on key indicators such as the duration of remote work and whether there is a commercial reason for an employee&rsquo;s presence in a jurisdiction. The article also outlines practical steps employers can take to mitigate tax risk and manage a globally distributed workforce.

Remote Work Without Borders But Not Necessarily Without Tax Consequences

Remote Work Without Borders—But Not Necessarily Without Tax Consequences: OECD Guidance for a Post-Pandemic World

Mackenzie Thomas

Lawyer at Bennett Jones Toronto

Issue 41 of Bennett Jones on Tax Disputes examines recent developments in Canadian tax litigation, with a focus on jurisdictional limits, procedural compliance, and case management in the Tax Court of Canada. Featuring commentary from members of the Bennett Jones Tax group, this edition analyzes key decisions including MEGlobal, Culig, and Opheim, and provides practical guidance for taxpayers and advisors navigating tax disputes.

Bennett Jones on Tax Disputes Issue 41

Bennett Jones on Tax Disputes: March 2026

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. 
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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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TEI Canada Bennett Jones Webinar on CRA Audit Initiatives

From the Same Authors