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Jared A. Mackey

Corporate Tax Lawyer at Bennett Jones Calgary

Partner

Anu Nijhawan

M&A, Corporate Financing and International Tax Lawyer at Bennett Jones Calgary

When Canadian multinationals issue discounted bonds, notes and similar obligations in a foreign currency, the tax consequences of repaying the debt are governed by subsections 39(2) and paragraph 20(1)(f) of the Income Tax Act (Canada). <a href="/People/M/Mackey-Jared">Jared Mackey</a> and <a href="/People/N/Nijhawan-Anu">Anu Nijhawan</a> explore the application and interaction of these provisions, which can give rise to unexpected results.

Tax Considerations on the Repayment of Discounted Foreign Currency Obligations

Hennadiy Kutsenko

Tax Lawyer at Bennett Jones Toronto

Associate

Incentivizing employees is a critical component of most business strategies. Employers may implement arrangements for deferred cash bonuses, often subject to the satisfaction of certain criteria. From a tax perspective, the efficacy of any such arrangement requires that no tax be payable prior to the time an individual receives a cash payout. To ensure that result, it is critical to avoid the application of the "salary deferral arrangement" rules under the Income Tax Act (Canada).

Incentivizing Employees Avoiding a Salary Deferral Arrangement

Incentivizing Employees: Avoiding a Salary Deferral Arrangement

Retirement compensation arrangements (RCAs) are, in appropriate circumstances, a useful tool for employers to provide supplemental pension benefits to employees, but such arrangements come at a cost of refundable tax under the Income Tax Act (Canada) (the ITA). The <a rel="noopener noreferrer" rel="noopener noreferrer" href="https://www.budget.canada.ca/2023/home-accueil-en.html" target="_blank">2023 Federal Budget</a> (the Budget), released on March 29, 2023 (Budget Day), proposes to amend the ITA to exempt, from the refundable tax, fees or premiums to the extent paid for the purposes of securing or renewing a letter of credit or a surety bond for an RCA structured as supplement to a registered pension plan.

Supplemental Pension Plans Secured with Letter of Credit Budget Proposes Refundable Tax Relief

Supplemental Pension Plans Secured with a Letter of Credit—Federal Budget 2023 Proposes Refundable Tax Relief

The Canadian Tax Foundation's newsletter Perspectives on Tax Law and Policy (June 2022) features an article by Anu Nijhawan and Jared Mackey on <a rel="noopener noreferrer" rel="noopener noreferrer" href="https://www.ctf.ca/CTFWEB/EN/Newsletters/Perspectives/2022/2/220205.aspx?_zs=J83WL1&_zl=IuCI2" target="_blank">Reimagining the Determination of Tax Avoidance</a>.

Canadian Tax Foundation Reimagining the Determination of Tax Avoidance

Canadian Tax Foundation: Reimagining the Determination of Tax Avoidance

Daron K. Naffin

Energy, Environmental/Regulatory and Expropriation Lawyer at Bennett Jones Calgary

Tim Myers

Regulatory, Environmental, Aboriginal and Expropriation Lawyer at Bennett Jones Calgary

Thomas Machell

Regulatory Lawyer at Bennett Jones Calgary

The Alberta Energy Regulator has released new editions of Directive 071 and Manual 026, significantly expanding emergency preparedness and response requirements. This post outlines the key changes, including mandatory Emergency Management Programs, expanded scope across resource sectors, enhanced hazard analysis standards, and what approval holders should do ahead of the February 2, 2026 effective date.

Alberta Energy Regulator Announces New Editions of Directive 071 and Manual 026

Serge Dupont

Senior Advisor at Bennett Jones Ottawa

Senior Advisor

The U.S. and global economies proved resilient in 2025. There were reasons, particularly around U.S. President Donald Trump&rsquo;s April 1 &ldquo;Liberation Day,&rdquo; to fear a global trade war or corrections in financial markets that would cause a recession in the United States and a sharp slowing of the global economy. In fact, while growth in the United States and most major economies slowed in 2025, other policy and market factors offset at least in part the early effect of disruptive policies by the U.S. administration. The United States&rsquo;s trading partners chose to avoid an all-out trade war, and most negotiated some form of accommodation with President Trump.

Economic Outlook 2026

Adapting to a New World: From Ambition to Investment

Ahmed Elmallah

Intellectual Property Lawyer at Bennett Jones Edmonton

Counsel, Patent Agent, Trademark Agent

Benjamin K. Reingold

Intellectual Property Litigation Lawyer at Bennett Jones Calgary

Stephen D. Burns

Technology Lawyer, Intellectual Property Lawyer at Bennett Jones Calgary

Partner, Trademark Agent

Stephen Thaler has appealed the Commissioner of Patents&rsquo; refusal to recognize his AI system, DABUS, as an inventor under the Patent Act. The case raises legal and practical questions as AI systems play a growing role in generating novel inventions. The outcome could influence how Canadian innovators protect AI-driven discoveries, particularly in pharmaceutical R&amp;D.

Appeal Filed Thaler Challenges Refusal to Recognize AI

Appeal Filed: Thaler Challenges Refusal to Recognize AI as an Inventor on a Patent—Implications Beyond Inventorship

Curtis A. Cusinato

Cross-border Mergers and Acquisitions and Capital Markets Lawyer at Bennett Jones Toronto

Vice Chair and Partner

Spencer Daniel

Lawyer at Bennett Jones Toronto

Nadia Plawiuk

In recent years, private equity investment in sports has surged globally, marking a transformative shift in the financial and operational landscape of professional athletics. The global sports market was valued at nearly US$516 billion in 2024, with forecasts projecting it will surpass US$893 billion by 2034. Major North American leagues, including the NFL, NBA, MLB, NHL and MLS have responded to this momentum by easing ownership restrictions since 2020, allowing private equity firms to acquire minority stakes and fueling increased deal activity. In 2024, minority investments accounted for 48% of deal volume, reflecting a growing trend in passive investment structures. Today, over 74 North American sports teams are backed or affiliated with private equity, with many more viewing private equity as a strategic growth partner amid rising team valuations and evolving monetization models.

How Private Equity is Changing the Game for North American Sports and Beyond

David Wainer

Commercial Transactions Lawyer at Bennett Jones Calgary

This end-of-year overview examines the Federal Government&rsquo;s rapid expansion of AI-related funding in 2025, from large-scale investments in data centres and public compute infrastructure to programs supporting AI access, adoption and domestic research. It also explores the new commitments announced in Budget 2025 and signals key trends to watch in 2026 as Canada strengthens its AI ecosystem.

Canadas AI Efforts in 2025 A Year in Review

Canada's AI Efforts in 2025: A Year in Review

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BennettJones

Nijhawan Anu

IRS Offers a Measure of but Incomplete Relief to Participants in Canadian Stock Based Compensation

IRS Offers a Measure of, but Incomplete, Relief to Participants in Canadian Stock-Based Compensation

Authors


Bennett Jones Update IRS Offers a Measure of, but Incomplete, Relief to Participants in Canadian Stock-Based Compensation August 1, 2005 Authors Anu NijhawanPartner Anu Nijhawan, "IRS Offers a Measure of, but Incomplete, Relief to Participants in Canadian Stock-Based Compensation Plans", (July/August 2005) XVII(1) Taxation of Executive Compensation and Retirement 572. Reprinted with the permission of Federated Press. Share by Email Social Media Download Download Subscribe Republishing Requests For permission to republish this or any other publication, contact Peter Zvanitajs at ZvanitajsP@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 Anu Nijhawan, Partner • Co-Head of Tax Department Calgary • 403.298.3389 • nijhawana@bennettjones.com