• About
  • Offices
  • Careers
  • News
  • Students
  • Alumni
  • Payments
  • EN | FR
Background Image
Bennett Jones Logo
  • People
  • Expertise
  • Knowledge
  • Search
  • FR Menu
  • Search Mobile
A B C D E F G H I J K L M N O P Q R S T U V W X Y Z
View all
Practices
Corporate Litigation Regulatory Tax View all
Industries
Energy Infrastructure Mining Private Equity & Investment Funds View all
Advisory
Crisis & Risk Management Public Policy
View Client Work
International Experience
Insights News Events Subscribe
Arbitration Angle Artificial Intelligence Insights Business Law Talks Podcast Class Actions: Looking Forward Class Action Quick Takes
Economic Outlook New Energy Economy Series Private Equity Briefings Quarterly Fintech Insights Quarterly M&A Insights
Sustainability & the CIO
People
Offices
About
Practices
Industries
Advisory Services
Client Work
Insights
News
Events
Careers
Law Students
Alumni
Payments
Search
Subscribe

Stay informed on the latest business and legal insights and events.

LinkedIn LinkedIn Twitter Twitter Vimeo Vimeo
 

Shopify Wins In Federal Court Against CRA In Merchant Data Case

June 04, 2025

The Federal Court dismissed two requests from the Canada Revenue Agency (CRA) that would have, if accepted, compelled Shopify to disclose six years of data from its merchants. The cases began in 2023 when the CRA filed a request for personal information about Shopify’s merchants.

The Court held that the application from the CRA for Shopify merchant data could not be authorized, as the CRA had failed to establish an “ascertainable group” of individuals in its filing. In a second decision, the Court rejected a CRA application made in response to a request from the Australian Tax Office. In arguing the case, the Minister of National Revenue indicated that the CRA’s application would serve as a test case for future applications on behalf of foreign tax authorities. In rejecting the CRA’s application, the Federal Court provided a robust analysis of the interaction of Canada’s treaties and the provisions of the Income Tax Act (Canada).

In its reasons, the Federal Court noted that the cases may serve as key precedents in the future.

Bennett Jones advised Shopify.

The Bennett Jones team was led by Brynne Harding (Litigation) and Jehad Haymour (Tax), and included Daphne Wang (Litigation) and Anna Lekach (Tax).

The full decisions are available here and here.

Related Links

  • Insights
  • Media
  • Subscribe

Related Expertise

  • Commercial Litigation
  • Tax
  • Tax Litigation & Dispute Resolution

Recent Posts

Client Work

Bennett Jones Advises Osisko Development on US$650 Million Financing Package for Cariboo Gold Project

August 20, 2025
       

Announcements

Dominique Hussey, Melanie Teetaert and Cheryl Woodin Recognized in Benchmark's Top 100 Women in Litigation

August 14, 2025
       

Announcements

Lamont Bartlett and Katherine Booth Ranked in 2025 Benchmark Litigation 40 & Under Hot List

August 14, 2025
       

Articles

Canadian Mining Journal: Deep Sea Mining Takes the International Stage

August 14, 2025
       

Client Work

J.S. Held Acquires GHL Consultants, Further Expanding in Canada

August 12, 2025
       

In The News

Serge Dupont on CBC’s The House on Canada’s Climate Goals – Aspirations and Reality

August 11, 2025
       

In The News

One Canadian Economy Act: Growing the Energy Sector Together

August 07, 2025
       

Announcements

Twenty-Five Bennett Jones Lawyers Ranked in Lexpert's Special Edition on Energy

August 06, 2025
       

In The News

The Lay of the Land in Energy Dealmaking

August 06, 2025
       
Bennett Jones Centennial Footer
Bennett Jones Centennial Footer
About
  • Leadership
  • Diversity
  • Community
  • Innovation
  • Security
Offices
  • Calgary
  • Edmonton
  • Montréal
  • Ottawa
  • Toronto
  • Vancouver
  • New York
Connect
  • Insights
  • News
  • Events
  • Careers
  • Students
  • Alumni
Subscribe

Stay informed on the latest business and legal insights and events.

LinkedIn LinkedIn Twitter Twitter Vimeo Vimeo
© Bennett Jones LLP 2025. All rights reserved.
  • Privacy Policy
  • Disclaimer
  • Terms of Use
Logo Bennett Jones