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Jared A. Mackey

Corporate Tax Lawyer at Bennett Jones Calgary

Partner

Article 4(1) of Canada’s income tax treaties defines a “resident” of a Contracting State to mean a person who is subject to comprehensive tax in that State “by reason of” various criteria, such as domicile, residence, place of management or any other criterion of a similar nature.

Deemed US Corporation not a US Treaty Resident

Deemed U.S. Corporation not a U.S. Treaty Resident: HRMC v. GE Financial Investments Ltd.

Edwin G. Kroft KC

Tax Litigation Lawyer at Bennett Jones

Andrew Young

Tax Lawyer at Bennett Jones Toronto

Associate

Spencer Brown

Tax Lawyer at Bennett Jones Calgary

Issue 35 of Bennett Jones on Tax Disputes, published on <a rel="noopener noreferrer" rel="noopener noreferrer" href="https://www.gettaxnetpro.com/" target="_blank">Taxnet Pro</a> by Thomson Reuters, features an overview of recent cases of note and cases under appeal. This issue contains two articles from members of Bennett Jones' tax group. <a href="/sitecore/service/notfound.aspx?item=core%3a%7bAB439BF8-7239-4964-BB51-FCB365B3EAF9%7d%40en">Spencer Brown</a> discusses the most recent Canada Revenue Agency guidance about the application of the general anti-avoidance rule and <a href="/sitecore/service/notfound.aspx?item=core%3a%7bDB12ADDA-AE46-4D3D-8597-13037E774E61%7d%40en">Andrew Young</a> comments on the recent Tax Court of Canada decision in Martin v the King, 2024 TCC 153. Issue 35 also contains summaries of recent tax decisions, tables regarding tax appeals and practice directives from the courts.

Bennett Jones on Tax Disputes - February 2025

Bennett Jones on Tax Disputes: February 2025

Jesse Fontaine

Commercial Transactions Lawyer at Bennett Jones Edmonton

Akash Purewal

Mullen Group Ltd. has announced its acquisition of Pacific Northwest Investments Inc. and its subsidiary Pacific Northwest Moving (Yukon) Limited. The acquisition, finalized on December 1, 2024, strengthens Mullen Group’s operations in the Yukon Territory and Northern Alberta. PNW, with over 50 years of experience, offers a range of less-than-truckload (LTL) solutions, including temperature-controlled, dry van and deck services, as well as local last-mile delivery in Whitehorse and Dawson City, YT.

Mullen Group Announces Acquisition of PNW Group

On October 29, 2024, the Canada Revenue Agency (CRA) <a rel="noopener noreferrer" href="https://www.canada.ca/en/revenue-agency/news/newsroom/tax-tips/tax-tips-2024/trust-reporting-for-the-2024-tax-year.html" target="_blank">issued a release</a> stating that it will not require bare trusts to file trust returns for the 2024 tax year, continuing the administrative exemption that was <a rel="noopener noreferrer" href="https://www.canada.ca/en/revenue-agency/news/newsroom/tax-tips/tax-tips-2024/bare-trusts-exempt-from-trust-reporting-requirements-2023.html" target="_blank">granted for the 2023 tax year</a>. The CRA's recent announcement follows on the heels of <a rel="noopener noreferrer" href="https://fin.canada.ca/drleg-apl/2024/ita-lir-0824-l-3-eng.html" target="_blank">proposed amendments</a> to the Income Tax Act (Canada) (the Proposed Amendments) released in August that, among things, would provide targeted reporting relief for bare trusts meeting certain criteria.

CRA Relief and Proposed Amendments Mitigate Bare Trust Reporting Burden on Energy Companies

Luke Morrison

Energy Project Development, M&A, and Commercial Transaction Lawyer at Bennett Jones Calgary

Ashley M. White

Corporate, Commercial Transactions, Power & Energy Lawyer at Bennett Jones Calgary

Pamela Clark

Lawyer at Bennett Jones Calgary 

Associate 

On June 6, 2025, the federal government introduced Bill C-5, An Act to enact the Free Trade and Labour Mobility in Canada Act and the Building Canada Act, which proposes new legislation aimed at strengthening Canada's economy by removing interprovincial trade and labour mobility barriers and advancing major projects.

Wind In The Sails of Canadian Energy Project Development

Wind In The Sails of Canadian Energy Project Development: Major Projects Office Open For Business, and Details of Fast-Tracked Projects Emerging

Stephen D. Burns

Technology Lawyer, Intellectual Property Lawyer at Bennett Jones Calgary

Partner, Trademark Agent

Matthew Flynn

Technology Transaction Lawyer at Bennett Jones Toronto

J. Sébastien A. Gittens

Intellectual Property and Technology Commercialization Lawyer at Bennett Jones Calgary

AI transcription tools offer efficiency and accuracy in the boardroom but create risks to confidentiality, privacy and legal privilege. Organizations should adopt clear policies, safeguards and training to ensure responsible use and compliance with governance standards.

AI Notetaking in the Boardroom

Lorelei Graham

Food and Agribusiness Lawyer, IP Lawyer, Litigation Lawyer at Bennett Jones Toronto

The United States Patent and Trademark Office's decision to cancel its Climate Change Mitigation pilot program for patents has not gone unnoticed in Canada. For Canadian policymakers and agri-tech innovators, this move by the United States raises two big questions: (1) How might this affect Canada&rsquo;s own intellectual property&nbsp; strategy for green tech, and (2) could it create opportunities for Canada (and others) to take the lead in certain climate-tech domains?
A particular area of interest is carbon-capture agri-tech, technologies that help farming not just reduce emissions but actively capture carbon (for instance, special crops or soil treatments that lock away carbon dioxide or farm machinery that traps greenhouse gases). These innovations are crucial for meeting climate goals and could become a competitive arena internationally.

Fast Tracks and Green Gaps Part IV

Fast Tracks and Green Gaps Part IV: Shifting Gears: How the United States' Exit from Climate Protection Fuels Canada's IP Advantage

Martin Ignasiak KC

Regulatory Lawyer at Bennett Jones Calgary

Jessica Kennedy

Larissa D. Lees

Alberta&rsquo;s updated self-supply rules create new opportunities for on-site power generation. This blog highlights key regulatory issues, risks, and opportunities developers need to consider.

So You Want to Supply Your Own Power Key Considerations for On Site Generation in Alberta

So You Want to Supply Your Own Power: Key Considerations for On-Site Generation in Alberta

Across the Atlantic, the European Union (EU) and its member states have also been encouraging climate-resilient agri-tech innovation, but their approach to intellectual property incentives has been a bit different. The European Union has set ambitious climate goals (like achieving climate neutrality by 2050) and launched the European Green Deal, a broad policy agenda to support sustainable technologies. While funding and regulations (such as support for sustainable farming practices) are big parts of the EU strategy, there is also recognition that IP rights play an important role in fostering innovation. However, unlike Canada or the recent US pilot program, Europe has not implemented a unified “green channel” for patent examination at the European Patent Office.

Fast Tracks and Green Gaps Part III

Fast Tracks and Green Gaps Part III: Green Without the Label: Europe's Pragmatic IP Approach to Agri-Tech Innovation

New Tax Reporting Requirements for Bare Trusts

Authors


Bennett Jones Article New Tax Reporting Requirements for Bare Trusts April 4, 2022 Authors Jared A. MackeyPartner Spencer BrownAssociate Jared Mackey and Spencer Brown write in The Lawyer's Daily on how Canadian bare trusts could soon be required to file annual returns with the Canada Revenue Agency. They answer key questions regarding bare trusts and note that those who fail to file annual reports could face substantial penalties. Jared and Spencer say that "pending legislative clarification from Finance or administrative guidance from the CRA, and given the severity of potential penalties for failure to file, many bare trustees will be forced to err on the side of filing a return." The full article can be found on The Lawyer's Daily website. Share by Email Social Media Download Download Subscribe Republishing Requests For permission to republish this or any other publication, contact Amrita Kochhar at kochhara@bennettjones.com. For informational purposes only This publication provides an overview of legal trends and updates for informational purposes only. For personalized legal advice, please contact the authors. Authors Jared A. Mackey, Partner Calgary • 403.298.4471 • mackeyj@bennettjones.com Spencer Brown, Associate Calgary • 403.298.3283 • brownsp@bennettjones.com