Issue 40 of Bennett Jones on Tax Disputes, published on Taxnet Pro by Thomson Reuters, reviews significant developments in Canadian tax litigation, highlighting recent court decisions and practical considerations for taxpayers navigating disputes. This edition features analysis and commentary from members of Bennett Jones’ Tax group.
Andrew Young examines Maragos v. The King, where the Tax Court confirmed that a director ceases to hold office upon a corporation’s dissolution and is not automatically reinstated upon revival, reinforcing the importance of statutory limitation periods and discouraging attempts to extend them through administrative action.
Antoine Messervier analyzes Brown v. The King, in which the Tax Court held that arrears interest on subsection 160(1) reassessments accrues from the date of the original assessment, underscoring the financial risks taxpayers face when challenging such assessments.
Zachary Thacker reviews Canada (National Revenue) v. Cohen, where the Federal Court declined to issue a compliance order after finding that the taxpayer had demonstrated reasonable efforts and cooperation in responding to broad information requests from the CRA.
This issue also includes a comprehensive Cases of Note section summarizing recent judgments across a range of procedural and substantive tax matters, offering timely insights into emerging litigation trends.
If you have any questions about the matters covered in this edition of Bennett Jones on Tax Disputes, please contact Ed Kroft KC, Chair of the Bennett Jones Tax Litigation and Dispute Resolution group.
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