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October 06, 2026
Appeal by appellant from a Tax Court order granting respondent an interim confidentiality order protecting certain documents during discovery in two tax proceedings.
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October 05, 2026
The Federal Court of Appeal has dismissed appeals over charitable donation tax credits claimed by appellants, affirming findings that the software licences donated by the taxpayers had little or no reliable proven value. In over 1,500 related cases, not one appeal was successful.
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October 02, 2026
The Supreme Court’s fall session is packed with interesting appeals in diverse areas of law including class actions, contracts, Crown immunity and Charter rights. The top court’s session begins Oct. 5 with an “opening of the court” ceremony in the West Memorial Building at 344 Wellington Street in Ottawa.
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October 02, 2026
1. Principal findings
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October 01, 2026
Mental health, job stress and keeping up with AI remain “front of mind” for the new president of Manitoba’s law society.
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October 01, 2026
Many people may be surprised and pleased to learn that there is a new path to becoming a Canadian citizen. The Government of Canada passed Bill C-3, An Act to Amend the Citizenship Act (2025), on Dec. 15, 2025. Before this legislation came into effect, Canadian citizenship by descent was limited to the first generation born outside Canada. For example, Emily was born or naturalized in Canada, and she could pass her citizenship to her child, Duncan, born outside of Canada.
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October 01, 2026
The New England Clean Energy Connect (NECEC) contract’s central weakness is the absence of a workable structure for an energy-only transaction during system stress. The parties appear not to have established how an energy-only commitment should operate when the seller has inadequate energy, capacity or water reserves to serve all demands.
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October 01, 2026
Hydro-Québec is a Crown corporation owned by the Quebec government. Unlike most U.S. utilities, its finances and policies are strongly shaped by the provincial government and the governing party’s policy objectives. Quebec has a regulatory agency, but it is also part of the provincial governmental structure.
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September 30, 2026
Supreme Court of Canada Justice Suzanne Côté says she finds intervener advocacy on Zoom to be as effective as oral submissions made in the courtroom, but she is also alive to contrary arguments made by legal organizations, such as the Canadian Bar Association and The Advocates’ Society.
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September 30, 2026
On Sept. 8, 2026, the parties to the New England Clean Energy Connect (NECEC) agreements filed federal complaints concerning Hydro-Québec’s interruption of deliveries to Massachusetts during the first two months of the 20-year agreement.
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September 29, 2026
Adam Nangini and Natasha Barrett have joined WeirFoulds as associates in its corporate and regulatory practice groups.
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September 29, 2026
The lengthy decision in Canada (National Revenue) v. Zeifmans LLP, 2026 FCA 147 in part involves a detailed analysis of the legal concepts of abuse of process and improper collateral attack as well as the relevant decisions in Canada (Customs and Revenue Agency) v. Artistic Ideas Inc., 2005 FCA 68 and Redeemer Foundation v. Minister of National Revenue, 2008 SCC 46.
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September 28, 2026
Section 84.1 of the Income Tax Act, the intergenerational transfer rules, has since 2024 contained a working exception for sales of a private company to a child’s corporation. Paragraph 84.1(2)(e) deems the vendor and the purchaser corporation to deal at arm’s length where the conditions of either ss. 84.1(2.31) or (2.32) are met, which switches off the deemed dividend and leaves the vendor with a capital gain eligible for the lifetime capital gains exemption — $1,275,000 for 2026. The conditions are not tax conditions. They are a statutory description of a vendor who has left the business, and the vendor’s counsel, not the accountant, is the one who has to make the client match it.
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September 28, 2026
The United States has launched tariffs under the Trump regime, and possibly future regimes, to counteract its decline as the world’s leading superpower. These tariffs impact valuation of any business engaged in global trade. To value such businesses, one must consider where the business operates, and whether that jurisdiction adjusted (i.e., Australia or Ireland, etc.), complied or negotiated a deal (i.e., the EU, Japan, U.K. and others), or retaliated (i.e., China or Canada).
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September 25, 2026
Barry Anthony Cullain owned one-third of an Ontario elevator maintenance business and was its vice-president of operations. The other two shareholders each held a third. While an acquisition financing was closing, they proposed to buy his shares. The financing failed. They took him off the payroll and said he had retired.
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September 25, 2026
Supreme Court of Canada Justice Suzanne Côté has significantly impacted the top court’s jurisprudence and culture since her appointment almost 12 years ago, says University of Alberta constitutional law professor Gerard Kennedy.
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September 25, 2026
Supreme Court of Canada Justice Suzanne Côté is thinking about what life after the bench might look like, she tells Law360 Canada. The court’s impactful and most prolific judge, who turned 68 this week with no apparent loss of drive or energy, says she is healthy and still loves the work that has earned her a reputation as a trailblazer and original thinker.
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September 24, 2026
A proposal to introduce three new federal income tax brackets for high earners would generate an additional $4.5 billion in net federal revenue over the 2026-27 to 2030-31 period, according to an estimate released by the Parliamentary Budget Office on Sept. 22.
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September 24, 2026
Part one of this series examined how the Federal Court of Appeal in Siam v. Canada, 2026 FCA 91 applied the Mpamugo v. The Queen, 2016 TCC 215 framework to a taxpayer’s claim that the Canada Revenue Agency (CRA) never sent his original Notice of Assessment.
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September 24, 2026
I used to advise clients who were involved in shareholder disputes. I would always ask whether the shareholders had been less than angelic in their dealings with each other and the tax department. Although businesspeople tend not to judge people who only steal from the tax department to be all that bad, for the sake of simplicity I will refer to both shareholders who steal from each other, and shareholders who steal from the tax department, as crooks.
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September 23, 2026
This is part one of a two-part series examining Siam v. Canada, 2026 FCA 91, in which the Federal Court of Appeal addressed a recurring evidentiary problem in tax reassessment litigation: what a taxpayer must actually prove when arguing that the Canada Revenue Agency never sent an original Notice of Assessment.
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September 23, 2026
Since March 26, 2026, every reporting entity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act must under the new s. 9.6(1.1) “ensure that the program is reasonably designed, risk-based and effective.” Its schedule entry is a very serious violation with a $20 million per violation ceiling for an entity ($4 million for a person). Little has been written about what s. 9.6(1.1) actually adds: an express program-level performance standard.
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September 22, 2026
Prince Edward Island will move to dismantle a 35-year-old quasi-judicial tribunal and replace it with two new decision-making bodies that will continue to deal with various appeals and disputes.
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September 22, 2026
In mergers and acquisitions (M&A) transactions, there is a constant struggle between the vendor and purchaser regarding risk allocation. This tension often arises from uncertainty regarding future performance, issues identified during due diligence and disagreements regarding value. One common mechanism for bridging that gap is an earnout, which makes part of the purchase price contingent on the post-closing performance of the target business.
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September 21, 2026
The Carney government says its proposed “Building Canada Strong” legislation and supporting Cabinet directive will ensure that federal reviews and decisions on major project proposals are completed within one year of a “comprehensive” submission by the project’s proponents. The 243-page Building Canada Strong Act (Bill C-39) was introduced in the House of Commons Sept. 21 by Transport Minister and Government House leader Steven MacKinnon.