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This article concludes our multi-part cryptocurrency tax litigation series by examining how disputes involving digital assets are ultimately resolved at trial before the Tax Court of Canada.

On January 14, 2026, the U.S. Federal Trade Commission ("FTC") announced that the dollar-based thresholds applicable to the Hart-Scott-Rodino ("HSR") premerger notification program will be raised about 5.9 percent from the 2025 levels. As a result, the HSR minimum size-of-transaction threshold will be raised to US$133.9 million from US$126.4 million. Transactions valued below the new US$133.9 million threshold will not require an HSR filing.

As an experienced Canadian tax lawyer specializing in tax audits and investigations, I often advise clients on the critical distinctions between tax audits and criminal investigations under Canadian tax legislation, whether conducted by the Canada Revenue Agency (CRA) or Revenu Québec.