Greg M. Johnson

Partner

T: 403.298.4470 / E: johnson@bennettjones.com

Calgary

Acting for clients in the energy industry, Greg Johnson's practice focuses on corporate tax, corporate reorganizations, mergers and acquisitions and private equity.

He is also a chartered accountant who practised with an international accounting firm before joining Bennett Jones.

Greg is a member of the Institute of Chartered Accountants of Alberta, a member of the Canadian Institute of Chartered Accountants, a member of the Canadian Tax Foundation, a director of the Canadian Petroleum Tax Society and an editor of the Federated Press Canadian Resource Taxation journal.

Select Experience

SECURE Waste Infrastructure Corp. (TSX: SES), a leading waste management and energy infrastructure company, in its $31-million acquisition of a metals recycling business
SECURE Waste Infrastructure Corp. (TSX: SES), a leading waste management and energy infrastructure company, in its $157-million acquisition of a metals recycling business
Killam Apartment REIT in a tax driven internal reorganization by way of a plan of arrangement
BofA Securities, Inc., CIBC World Markets Corp. and RBC Capital Markets, LLC in connection with the remarketing of Algonquin Power & Utilities Corp.'s US$1.15-billion aggregate principal amount of 1.18% Senior Notes
SECURE Energy Services Inc. in its $1.075-billion asset sale of waste management facilities pursuant to a divesture order by the Competition Tribunal
Riverstone Pipestone LP and Riverstone V REL CNOR LP, the largest shareholders of Pipestone Energy Corp., in connection with the acquisition by Strathcona Resources Ltd. of all of the outstanding shares of Pipestone pursuant to a plan of arrangement
Riverstone Holdings LLC, in its acquisition of all issued and outstanding Class A common shares of Hammerhead Energy Inc. by Crescent Point Energy Corp. by an arrangement agreement for total consideration of approximately $2.55-billion, including approximately $455-million in assumed net debt, consisting of cash and common shares of the Purchaser
NGP Energy Capital Management, LLC in its investment in Cygnet Energy Ltd., a private company focused on capturing scalable resource opportunities in the Western Canadian Sedimentary Basin
Riverstone Holdings LLC, through its subsidiary Riverstone Pipestone LP, in its investment in the $67.9-million private placement of convertible preferred shares of Pipestone Energy Corp
Rangeland Energy, in connection with the sale of Rangeland Midstream Canada Ltd., whose principal assets include the Marten Hills Pipeline System, to Kingston Midstream Alberta Limited
Repsol Oil & Gas Canada Inc. in its US$468-million sale of all partnership interests of Repsol Canada Energy Partnership to Peyto Exploration & Development Corp
Gibson Energy Inc., as Canadian counsel, in its US$1.1-billion acquisition of South Texas Gateway Terminal LLC
Nippon Steel Corporation in its $1.15-billion investment in Elk Valley Resources Ltd., a steelmaking coal business to be spun-out as an independent public company from Teck Resources Ltd.
BP Canada Energy Group ULC, as tax counsel in the sale of its 50% stake in the Sunrise oil sands project in northern Alberta to Cenovus Energy Inc.
Xie Florida Holdings, Inc. in its sale of Brightech International, LLC to Arlington Capital Partners and Everest Clinical Research
The Patrick D. Bowlen Trust, as Canadian tax and corporate counsel, in its US$4.65-billion sale of the Denver Broncos NFL franchise to the Walton-Penner group
Alcanna Inc. in its approximately $320-million acquisition by Sundial Growers Inc.
ValOre Metals Corp. in closing its "best efforts" brokered private placement for gross proceeds of $11-million
SECURE Energy Services Inc., in its $2-billion acquisition of Tervita Corporation
SECURE Energy Services Inc., in its $200-million private placement of senior unsecured notes due 2026
Homestyle Selections LP, through its portfolio company Freshstone Brands Inc., in the US$30-million acquisition of the assets and business of Tiffany Gate Foods Inc. and all of the Ontario-based assets of Sun Rich Fresh Foods. The acquisition was completed through a Stalking Horse sale process conducted under the CCAA
PFS Genomics Inc. in the US$30.6-million sale of a 90% interest to 1300342 B.C. Ltd., a wholly-owned subsidiary of Exact Sciences RDX LLC
OPTrust, in connection with the formation and limited recourse financing of a partnership with six Alberta First Nations which in turn participated in the equity syndication and project financing of the $1.5-billion Cascade Power Project to be developed near Edson, Alberta and operated by Calgary based developer Kineticor.
Riverstone Holdings LLC, as Canadian counsel, in its agreement to acquire International-Matex Tank Terminals from Macquarie Infrastructure Corporation for US$2.7 billion
First Majestic Silver Corp., in an equity distribution agreement with BMO Capital Markets Corp. and TD Securities (USA) LLC for the sale of up to US$100.0 million of common shares
MEG Energy Corp., in its private placement of US$1.2-billion aggregate principal amount of 7.1250% senior unsecured notes due 2027 in the United States and Canada
Killam Properties Inc., on matters related to public offering of trust units, purchasing and financing and properties, structuring of joint ventures and credit facilities
Parkland Fuel Corporation completes US$500,000,000 Note Offering
Schlumberger Production Management, on the purchase of the Palliser Block assets in Alberta from Cenovus Energy Inc. for cash consideration of $1.3 billion
Shore Gold Inc., in the acquisition of all of Newmont Mining Corporation's participating interest in the Star-Orion Diamond Mine Project and an option to joint venture agreement and a private placement of $1,000,000 with Rio Tinto Exploration Canada Inc.
Riverstone Holdings LLC / Niska Gas Storage Canada ULC, in an offering of US$800 million of unsecured notes and a US$400-million secured operating facility
Parkland Fuel Corporation, in its $662-million common share private placement offering and $500 million 5.625% high yield note private placement offering to partially fund Parkland's proposed acquisition of Chevron Canada's Canadian integrated downstream fuel business for $1,460 million plus an estimated $186 million in working capital
Parkland Fuel Corporation, in completing $230,000,000 private placement of subscription receipts
Parkland Fuel Corporation, in completing $300,000,000 high yield debt offering.
Edge Natural Resources LLC, in the acquisition of Canamax Energy Ltd. by Edge and senior management and certain other shareholders of Canamax in a transaction valued at approximately $82 million
Parkland Fuel Corporation, North America's fastest growing distributor and marketer of fuels and lubricants, in connection with its proposed $378 million purchase of assets of Pioneer Energy
Parkland Fuel Corporation, in a $200-million high yield note offering in Canada
On April 1, 2014, Newalta Corporation announced the completion of a private placement by way of offering memorandum of $150,000,000 aggregate amount of 5.875% Series 3 Senior Unsecured Debentures, due April 1, 2021
Pine Cliff Energy Ltd., (TSXV: PNE) in a $25-million public offering of common shares on a bought deal basis
Parallel Energy Trust – $125 million public offering of trust units and convertible debentures – counsel to underwriters, led by Scotia Capital Inc., RBC Capital Markets and CIBC World Markets Inc.
Shell Canada Limited, in its approximately $8.7-billion acquisition by Shell Investments Limited, a wholly-owned subsidiary of Royal Dutch Shell plc
Parkland Income Fund, in its $135-million acquisition of Neufeld Petroleum and Propane Ltd. and Neufeld Holdings Ltd.
Parkland Income Fund, in its $50-million public offering of trust units on a bought deal basis
Pengrowth Energy Trust, in its approximately $1.1-billion acquisition of Canadian oil and gas properties and undeveloped lands through the acquisition of the shares of four subsidiaries of ConocoPhillips Canada
Pengrowth Energy Trust, in its $461-million equity offering to a syndicate of underwriters led by RBC Capital Markets
BNP Paribas, in the completion of a cross-border US$180-million term loan B facility and a US$15-million working capital facility for Connacher Finance Corporation, the proceeds of which were used to finance the construction of Connacher's oil sands project in Northern Alberta and finance the operation of a refinery in Montana
Pengrowth Energy Trust, in $1.3-billion acquisition of Esprit Energy Trust
Pengrowth Energy Trust, in an offering of 23,310,000 trust units for gross proceeds of $526 million
Korea National Oil Corporation, in its $310-million acquisition of a 100 percent interest in the BlackGold oil sands assets of Newmont Mining Corporation of Canada Limited, a subsidiary of Denver-based Newmont Mining Corporation
Pengrowth Energy Trust, in its consolidation of Class A trust units and Class B trust units into a single class of trust units, with a total market capitalization greater than $4 billion
North West Upgrading Inc., in a $175-million private placement of units at a price of $4.00 per unit to investors in North America and Europe, each unit consisting of a common share and one-half of one common share purchase warrant
Peters & Co. Limited, as agent, in a private placement financing of subscription receipts by Orleans Energy Ltd. valued at $38 million
The syndicate of underwriters, led by Peters & Co. and including GMP Securities Ltd., Tristone Capital Inc., Dundee Securities Corporation and National Bank Financial Inc., in the acquisition of Mercury Energy Corporation by Orleans Energy Ltd. for approximately $21 million
Peters & Co. Limited, as agent, in its private placement financing of common shares of TriAxon Resources Limited
Peters & Co. Limited, as agent, in its acquisition of Bredal Limited Partnership for $8 million
Peters & Co. Limited, as agent, in its acquisition of LILT Canada Inc. by TriAxon Resources Limited for $5 million
Carlyle/Riverstone Global Energy and Power Fund, in the fund's US$1.2-billion acquisition of EnCana Corporation's gas storage business, now known as Niska Gas Storage
Corridor Resources Inc., in a public offering of common shares for gross proceeds of approximately $40 million
NUCRYST Pharmaceuticals Corporation and The Westaim Corporation, in NUCRYST's US$45-million cross-border initial public offering, which was concurrently offered in Canada and the United States
Fun Sun Vacations, in its merger with V.I.T. Voyages Intair Transit Inc., to create Canada's leading FIT tour operator and air consolidator
Avalon Resources Ltd., in the sale of all of its outstanding common shares to Atlas Energy Limited for a cash and share consideration of $49.44 million
Synenco Energy Inc., in a $317-million initial public offering of class A voting shares which included exercise of an over-allotment option
Deer Creek Energy Limited, in its acquisition by Total E&P Canada Limited (a subsidiary of Total S.A.) by way of a takeover bid for approximately $1.6 billion
Pengrowth Energy Trust, in the $299 million offering of trust units
Temple Exploration Inc., in the $115-million acquisition of the company by Husky Energy
Ultima Energy Trust, in a $500-million merger with Petrofund Energy Trust
NAL Oil & Gas Trust and an institutional investor, in the acquisition of working interests in various oil and gas properties from Nexen Petroleum Canada for $278.5 million
NAL Oil & Gas Trust, in its $123 million public offering of trust units
Pengrowth Energy Trust, in its $245 million public offering of trust units

Recent Recognitions

Lexpert Special Edition—Canada's Leading Restructuring and Insolvency Lawyers

Recognized as a leading Restructuring and Insolvency lawyer
Chambers Canada

Ranked, Tax
Chambers Global

Band 4, Tax
Canadian Legal Lexpert Directory

Most Frequently Recommended, Corporate Tax
Best Lawyers in Canada

2022 Calgary Lawyer of the Year, Tax Law
Recognized as one of Canada's leading Tax and Mergers and Acquisitions lawyers
Canadian Petroleum Tax Society

Granted the Vince Bjorndahl Award for excellence in Legal Writing and Tax Analysis
Lexpert/Report on Business Special Edition - Canada's Leading Energy Lawyers

Recognized as a leading Energy lawyer in Canada
Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada

Ranked, Corporate Tax
Lexpert Special Edition—Canada's Leading Finance and M&A Lawyers

Recognized as a leading Finance and M&A lawyer

Recent Insights, News & Events

156 Bennett Jones Lawyers Featured in 2025 Canadian Legal Lexpert Directory
Announcements / March 11, 2025
The Canadian Legal Lexpert Directory has recognized 156 Bennett Jones lawyers in the 2025 edition. The firm also received rankings across 32 practice areas.
Chambers Global Ranks Bennett Jones Lawyers in 2025 Guide
Announcements / February 13, 2025
Bennett Jones has been recognized in the Chambers Global Guide 2025, with 49 lawyers ranked across 19 practice areas. Clients in Canada and around the world trust us to navigate their most complex legal matters. Our inclusion in Chambers Global Guide 2025 highlights our commitment to an exceptional client experience, deep industry knowledge and long-standing client relationships.
Twenty-One Bennett Jones Lawyers Recognized in 2025 Lexpert Leading 500 Cross Border Lawyers
Announcements / January 14, 2025
Twenty-one Bennett Jones lawyers are recognized as leading lawyers in the 2025 Lexpert 500 Cross Border Directory (formerly ALM 500). This recognition underscores Bennett Jones' dedication to helping clients with their most complex legal matters. The Lexpert 500 Cross Border Directory profiles the most frequently recommended lawyers across Canada in approximately 35 practice areas identified via an extensive, annual peer survey. Lexpert produces the Directory in collaboration with American Lawyer Media.
Unlocking Green Growth: Further Clean Economy ITC Expansions Announced in Canada's 2024 Fall Economic Statement
Blog / December 17, 2024
The Government of Canada advanced its clean energy agenda in the 2024 Fall Economic Statement (FES 2024) by expanding and providing further guidance on several key clean economy investment tax credits (ITCs) designed to accelerate the country's transition to a low-carbon economy. FES 2024 provides further guidance for the Clean Electricity Investment Tax Credit (CE ITC) and the Electric Vehicle (EV) Supply Chain Investment Tax Credit (EV ITC) and announces a further “eligible pathway” that is proposed to be added for the Clean Hydrogen Investment Tax Credit (Clean Hydrogen ITC).
Harnessing the Power of Clean Economy Investment Tax Credits
Articles / November 28, 2024
Geoff Stenger, Greg Johnson and Brendan Sigalet write the legal feature column in ReNew Canada on how companies can make the most of federal investment tax credits (ITCs) for clean energy projects in Canada.
10 Lawyers Recognized in Lexpert Special Edition: Restructuring and Insolvency 2024
Announcements / October 17, 2024
We are pleased to announce that 10 Bennett Jones lawyers have been ranked in the Lexpert Special Edition: Restructuring and Insolvency 2024, reflecting our team's deep expertise in handling complex insolvency and restructuring cases. This issue highlights how companies in Canada can navigate the mounting economic pressures.
Canadian Natural Resources Limited Announces Acquisition of Chevron's Alberta Assets for US$6.5 Billion
Client Work / October 07, 2024
Canadian Natural Resources Limited announced that it entered into an agreement to acquire, subject to regulatory approvals, from Chevron Canada Limited its 20 percent interest in the Athabasca Oil Sands Project (AOSP), which includes 20 percent of the Muskeg River and Jackpine mines, the Scotford Upgrader and the Quest Carbon Capture and Storage facility. This acquisition brings Canadian Natural’s total current working interest in AOSP to 90 percent.
Bennett Jones Top Ranked in Chambers Canada 2025
Announcements / September 26, 2024
Bennett Jones is proud to have once again been recognized as one of Canada’s leading law firms across 41 practice areas, with 135 lawyer rankings in Chambers Canada 2025. These rankings reflect the deep trust our clients place in us to solve their most complex legal matters and underscore our lawyers' extensive understanding of their industries and businesses, enabling us to consistently deliver an exceptional experience. In this year's guide, Bennett Jones has 10 Band 1 practice rankings, 20 Band 1 lawyer rankings and 10 newly-ranked lawyers. In addition to this year's rankings, Bennett Jones was awarded Class Action Law Firm of the Year and was a finalist for Real Estate Law Firm of the Year.
SNDL to Acquire Remaining Minority Interest of Nova Cannabis
Client Work / August 13, 2024
SNDL Inc. and Nova Cannabis Inc. have announced that they have entered into an arrangement agreement pursuant to which SNDL will acquire all of the issued and outstanding common shares in the capital of Nova not already owned by SNDL, representing approximately 34.8 percent of Nova shares, by way of a statutory plan of arrangement for aggregate consideration of approximately C$40 million. Bennett Jones is acting as legal counsel to Nova.
Budget 2024 Provides Additional Details for the Clean Electricity ITC and Adds Another ITC for Electric Vehicles
Blog / April 19, 2024
In Budget 2024, the Government of Canada continued their drive to implement government incentives aimed at decarbonizing the economy through providing further clarification and design details for the Clean Electricity investment tax credit, and through providing an additional tax credit for electric vehicle manufacturers in the form of the EV Supply Chain ITC.
Twenty-Seven Bennett Jones Lawyers Ranked in Lexpert's Special Edition on Finance and M&A
Announcements / April 18, 2024
Twenty-seven Bennett Jones lawyers are ranked in the April 2024 Lexpert Special Edition—Finance and M&A. The annual feature profiles Lexpert-ranked lawyers in in Corporate Finance, M&A and related practices.
Government of Alberta Unveils Further Details Regarding the Alberta Carbon Capture Incentive Program
Blog / April 09, 2024
On April 3, 2024, the Alberta Government released additional details on the Alberta Carbon Capture Incentive Program (ACCIP), which will support and accelerate the development of new carbon capture, utilization and storage infrastructure in Alberta. It is now open for industry and carbon sequestration hub operators to apply for ACCIP pre-approval, and the ACCIP rollout now includes more detail around the ACCIP's key features, eligibility criteria, eligible costs and the application process.
167 Bennett Jones Lawyers Recognized in the Canadian Legal Lexpert Directory 2024
Announcements / March 06, 2024
167 Bennett Jones lawyers have been recognized for their legal expertise in the 2024 edition of the Canadian Legal Lexpert Directory.
Chambers Global Ranks Bennett Jones Lawyers in 2024 Edition
Announcements / February 15, 2024
Bennett Jones has 49 lawyer rankings across 19 practice areas in Chambers Global 2024. Chambers and Partners is an independent research company operating across 200 jurisdictions delivering 49 detailed rankings and insight into the world's leading lawyers.
SECURE Energy Services Inc.: $1.075 Billion Asset Sale of Waste Disposal Facilities
Client Work / February 01, 2024
Bennett Jones successfully advised SECURE Energy Services Inc., in its $1.075 billion asset sale of waste disposal facilities to R360 Canada Environmental Solutions Inc., an affiliate of Waste Connections of Canada Inc. The sale marks the end of a divestment process for certain assets formerly owned by Tervita Corporation ordered to be sold by the Competition Bureau.
Twenty-Three Bennett Jones Lawyers Recognized in 2024 Lexpert ALM 500 Directory
Announcements / January 22, 2024
Twenty-three Bennett Jones lawyers are recognized in the 2024 Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada. The Lexpert/ALM 500 Directory profiles the most frequently recommended lawyers across Canada in approximately 35 practice areas identified via an extensive, annual peer survey. Lexpert produces the Directory in collaboration with American Lawyer Media.
Government of Canada Releases Proposed Legislation for Clean Hydrogen ITC and Clean Manufacturing ITC
Blog / January 17, 2024
On Tuesday, December 20, 2023, the Federal Government released proposed legislation for the implementation of the clean hydrogen investment tax credit (the Clean Hydrogen ITC) and the clean manufacturing investment tax credit (Clean Manufacturing ITC).
Climate Change Initiatives: Selected Recent Changes and the Application of Existing Tax Principles to Clean Energy—Part 1
Articles / January 04, 2024
Greg Johnson, Wesley Novotny and Brendan Sigalet write for the Resource Sector Taxation journal on Federal tax policies aimed at reducing greenhouse gas emissions by incentivizing clean energy technologies. The article reviews various proposed initiatives and existing incentives, emphasizing their integration with existing legislation and the importance of providing certainty to businesses making investment decisions.
Canada's Clean Tech Push & Alberta's Carbon Incentive
Blog / December 04, 2023
On Tuesday, November 28, the Federal Government released a Notice of Ways and Means Motion for the implementation of certain provisions of the November 2023 Fall Economic Statement and March 2023 Budget. On the same day, the Alberta Government introduced a new Alberta Carbon Capture Incentive Program. Such announcements were made ahead of the annual COP28 climate conference being held in Dubai, United Arab Emirates.
Pension Investment Association of Canada Tax Conference
Speaking Engagements / October 24, 2023
Wesley Novotny and Greg Johnson presented at the 2022 PIAC (Pension Investment Association of Canada) Tax Conference on “Tax-exempt status under paragraph 149(1)(o.2)”.
Bennett Jones Top Ranked in Chambers Canada 2024
Announcements / September 28, 2023
Bennett Jones has been recognized as one of Canada’s leading law firms across 39 practice areas, with 124 lawyer rankings in Chambers Canada 2024. In this year's guide, Bennett Jones has 11 Band 1 practice rankings, 21 Band 1 lawyer rankings and 10 newly-ranked lawyers. In addition to this year's rankings, Bennett Jones was awarded Real Estate Law Firm of the Year and was a finalist in Projects and Energy Law Firm of the Year.
24th World Petroleum Congress
Event / September 17, 2023
As a frontrunner in the energy industry for the last century, Bennett Jones is proud to be the Official Legal Sponsor of the 24th World Petroleum Congress. The conference provides a unique opportunity to work together to develop realistic and workable paths to a net-zero future.
Bennett Jones Lawyers Recognized in Best Lawyers in Canada 2024
Announcements / August 24, 2023
104 Bennett Jones lawyers have been recognized across 46 practice areas in the 2024 edition of Best Lawyers in Canada. The recognized lawyers work in Bennett Jones' offices across Canada in Calgary, Edmonton, Toronto and Vancouver, highlighting the firm's national expertise.
Federal Government Releases Legislative Proposals for Clean Technology Investment Tax Credit
Blog / August 17, 2023
On August 4, 2023, the Federal Government released proposed legislation for the Clean Technology Investment Tax Credit (Clean Tech ITC), as proposed by the 2022 Fall Economic Statement (the 2022 FES) and as modified by Budget 2023. The proposed legislation largely conforms to what was previously announced, as we previously discussed following the original announcement of the Clean Tech ITC in the 2022 FES.
The Drive to Decarbonize—An Overview of Recent Clean Energy Tax Initiatives
Speaking Engagements / May 04, 2023
Greg Johnson and Brendan Sigalet presented to the Canadian Petroleum Tax Society today about recent clean energy tax initiatives.
Canada Using the Carrot Instead of the Stick to Decarbonize in Budget 2023
Blog / March 30, 2023
The Government of Canada continued their drive to decarbonize the economy through the use of the carrot rather than the stick in Budget 2023 by announcing two new investment tax credits (1) A Clean Electricity Investment Tax Credit, and (2) A Clean Technology Manufacturing Tax Credit.
Chambers Global Ranks Bennett Jones Lawyers in 2023 Edition
Announcements / March 06, 2023
Bennett Jones has 50 lawyer rankings across 19 practice areas in Chambers Global 2023. Chambers and Partners is an independent research company operating across 200 jurisdictions delivering detailed rankings and insight into the world's leading lawyers.
Nippon Steel Commits to $1.15 Billion Investment in Elk Valley Resources in Teck Spin Off
Client Work / February 22, 2023
Bennett Jones is representing Nippon Steel Corporation in its proposed $1.15 billion investment in Elk Valley Resources Ltd. (EVR), a steelmaking coal business to be spun-out as an independent public company from Teck Resources Ltd. Nippon Steel and EVR have agreed that concurrently with the completion of the investment, they will enter into long-term coal offtake rights agreement, under which EVR will supply steelmaking coal to Nippon Steel.
Twenty-One Bennett Jones Lawyers Recognized in 2023 Lexpert ALM 500 Directory
Announcements / February 06, 2023
Twenty-one Bennett Jones lawyers are recognized in the 2023 Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada. The Lexpert/ALM 500 Directory profiles the most frequently recommended lawyers across Canada in approximately 35 practice areas identified via an extensive, annual peer survey. Lexpert produces the Directory in collaboration with American Lawyer Media.
Canadian Investment Tax Credits for Clean Technologies and Clean Hydrogen Announced in 2022 Fall Economic Statement
Blog / November 15, 2022
One of the defining aspects of the Government of Canada's 2022 Fall Economic Statement that was announced on November 3, 2022, is its response to the Inflation Reduction Act in the United States. The IRA, signed into law by President Joe Biden on August 16, 2022, offers enormous financial incentives to the clean energy industry in the transition to a net-zero economy.
Tax-exempt Status Under Paragraph 149(1)(o.2)
Speaking Engagements / October 24, 2022
Wes Novotny and Greg Johnson were featured speakers on Tax-exempt Status Under Paragraph 149(1)(o.2) at the Pension Investment Association of Canada's Tax Conference. The conference was hosted in Toronto on October 24 and 25 and offered tax professionals discussions and seminars on current tax issues impacting the pension industry.
Canadian Budget Proposes New Investment Tax Credit For Carbon Capture, Utilization and Storage
Blog / April 12, 2022
The 2022 Canadian Federal Budget, released on April 7, 2022, sets the fundamental groundwork of the Government of Canada's goals for national economic development. Following Canada's announcement of its 2030 Emissions Reduction Plan on March 29, 2022, for achieving a net-zero economy by 2050, the Budget establishes a refundable investment tax credit for Carbon Capture, Utilization and Storage (CCUS) beginning in 2022. The Budget did not provide specific proposed legislation for the CCUS Tax Credit. As a result, there could be differences between the form of future proposed legislation and the Budget and such differences could be material.
Supreme Court of Canada Upholds Treaty-Based Canadian Holding Structure
Blog / December 17, 2021
On November 26, 2021, the Supreme Court of Canada (the SCC) released its highly anticipated decision in Canada v Alta Energy Luxembourg SARL, 2021 SCC 49 [Alta Energy Lux], that addressed treaty-based holding structures and the application of the general anti-avoidance rule (GAAR). In a 6-3 majority, the SCC held that the GAAR did not apply to the transactions at issue which resulted in the taxpayer, Alta Energy Luxembourg S.A.R.L. (Alta Lux), not being subject to Canadian tax on the gain realized on the sale of its Canadian oil and gas subsidiary based on the provisions of Canada-Luxembourg Tax Treaty (the Lux Treaty).
Bennett Jones: "Top Tier" in Chambers Canada 2022
Announcements / September 16, 2021
Bennett Jones has been recognized as one of Canada’s leading law firms across 38 practice areas, with 111 lawyer rankings in Chambers Canada 2022. Bennett Jones has 8 Band 1 practice rankings and 14 Band 1 lawyer rankings in this year's guide.
Bennett Jones' Best Lawyers in Canada 2022
Announcements / August 26, 2021
146 Bennett Jones lawyers have been recognized across 48 practice areas in the Best Lawyers in Canada 2022 edition, with 44 lawyers having earned recognition in multiple practice areas. The recognized lawyers work in Bennett Jones' offices across Canada in Calgary, Edmonton, Toronto and Vancouver, highlighting the firm's national expertise.
159 Lawyers in Canadian Legal Lexpert Directory
Announcements / April 29, 2021
159 Bennett Jones lawyers have been ranked in the annual edition of The Canadian Legal Lexpert Directory. 26 are in the highest category of Most Frequently Recommended.
36 Bennett Jones Lawyers in Lexpert's Special Edition on Finance and M&A
Announcements / April 16, 2021
Thirty-six Bennett Jones lawyers are ranked in the 2021 Lexpert Special Edition – Canada's Leading Finance and M&A Lawyers.
Exploring International Energy Investments During and Post Pandemic
Speaking Engagements / March 26, 2021
Duncan McPherson and Greg Johnson speak on Tax Incentive Applications in Transition to Electric Vehicles and EV Fleets – Comparing Australia, Canada & US.
Bennett Jones in Chambers Global 2021
Announcements / February 21, 2021
Bennett Jones has 51 lawyer rankings in 18 practice areas in Chambers Global 2021. Chambers and Partners is an independent research company operating across 200 jurisdictions delivering detailed rankings and insight into the world's leading lawyers.
Bennett Jones Acts for Canadian Power Deal of the Year in Cascade Power Project
Client Work / January 11, 2021
Bennett Jones congratulates the Cascade Power Project for winning Project Finance International's (PFI) Canadian Power Deal of the Year award for 2020. Bennett Jones acted as counsel to Ontario-based pension fund and project sponsor OPTrust in connection with the transaction.
Flow-Through Shares: Draft Legislation Released to Extend Expenditure Periods
Blog / December 18, 2020
On December 16, 2020, the Department of Finance released draft legislation aimed at providing relief to resource companies that had issued (or will issue prior to the end of 2020) "flow-through shares" [...]
Twenty-Five Bennett Jones Lawyers in Lexpert/ALM 500 Directory
Announcements / December 17, 2020
Twenty-five Bennett Jones lawyers are recognized in the 2021 Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada.
Bennett Jones Leads Canada in Energy Law
Announcements / October 26, 2020
Bennett Jones has 52 lawyers ranked in Lexpert's Special Edition: Energy 2020—more than any other law firm in Canada. Ranked lawyers provide services in oil & gas, electricity, alternative and nuclear energy. Bennett Jones has been intimately involved in virtually every major energy development project in Canada in the past 20 years, representing project proponents, investors and other stakeholders.
Bennett Jones is Recognized in Chambers Canada 2021
Announcements / September 10, 2020
Bennett Jones has been recognized as one of Canada’s leading law firms across 38 practice areas, with 115 lawyer rankings in Chambers Canada 2021.
The Multilateral Instrument and Canadian Tax Planning Considerations: The Clock is Ticking
Blog / July 20, 2020
The clock is ticking for multinational enterprises and private equity firms with investments in the Canadian resource sector as anti-treaty shopping measures in the OECD's Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) begin to take effect.
Extended Federal Tax Filing, Payment and Remittance Deadlines Amid COVID-19
Blog / March 31, 2020
As part of Canada's COVID-19 Economic Response Plan announced on March 18, 2020, and through subsequent press releases, the Department of Finance and the Canada Revenue Agency have extended a number of federal tax filing, payment and remittance deadlines.
COVID-19 Tax Updates from the Alberta Government and the CRA
Blog / March 20, 2020
Since March 18, 2020, the following updates have been released by the Government of Alberta and the Canada Revenue Agency (CRA) regarding their respective economic relief plans to help mitigate the effects [...]
Canada's COVID-19 Economic Response Plan
Blog / March 19, 2020
On March 18, 2020, the federal government announced Canada's COVID-19 Economic Response Plan, containing a number of measures to be implemented by the Department of Finance to help manage the financial hardships Canadians are experiencing during the COVID-19 outbreak.
Federal Court of Appeal Upholds Treaty-Based Canadian Holding Structure
Blog / February 26, 2020
In Canada v Alta Energy Luxembourg S.A.R.L., 2020 FCA 43, the Federal Court of Appeal concluded that the Canada-Luxembourg tax treaty was not abused when a Luxembourg resident sold shares of a Canadian resource company in circumstances where a greater than $380-million capital gain realized on the sale was exempt from taxation in Canada.
Bennett Jones in Chambers Global 2020
Announcements / February 13, 2020
Bennett Jones has 50 lawyer rankings in 17 practice areas around the world in Chambers Global 2020.
Bennett Jones' Leading Lawyers in Chambers Canada 2020
Announcements / September 19, 2019
Bennett Jones has been recognized as one of Canada’s leading law firms with over 100 recognized practitioners nationally in Chambers Canada 2020. Here are a few things clients have said: “The [...]
Tax Treaty Benefits Threatened as Canada Completes Ratification of OECD's Multilateral Instrument
Blog / September 05, 2019
On August 29, 2019, Canada completed its domestic ratification of the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI). [...]
Bennett Jones Leads Canada in Energy Law
Announcements / September 02, 2019
Bennett Jones has 49 lawyers ranked in Lexpert’s 2019 Special Edition—Canada’s Leading Energy Lawyers, more than any other firm. The rankings appear in the Globe and Mail’s Report on Business magazine.
Resource Industry Panel
Speaking Engagements / June 06, 2019
Greg Johnson moderates the Resource Industry Panel at the Canadian Petroleum Tax Society's 2019 Annual Conference.
Bennett Jones Speaks before Senate Committee on Tax Issues for Energy Investments
Blog / May 30, 2019
On May 29, 2019, Darcy Moch, Greg Johnson and Jared Mackey of Bennett Jones participated on a witness panel before the Standing Senate Committee on Foreign Affairs and International Trade to discuss the [...]
New Ratifications of the OECD's Multilateral Instrument Put Canadian Resource Holding Structures at Risk
Updates / April 03, 2019
Tax-efficient holding structures commonly used by multinational enterprises and private equity firms investing in the Canadian resource sector could soon become subject to anti-treaty shopping measures contained in the "Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting".
Bennett Jones in Chambers Global 2019
Announcements / February 14, 2019
Bennett Jones has 48 lawyer rankings in 15 practice areas around the world in Chambers Global 2019.
The 2018 Federal Fall Economic Statement—Canada's Response to U.S. Tax Reform
Updates / December 04, 2018
Roughly one year after U.S. tax reform, the Department of Finance has introduced amendments to Canada's income tax laws aimed at encouraging investment in Canada. The proposed changes included in the [...]
Tax Court Affirms Treaty-Based Canadian Holding Structure
Blog / September 04, 2018
The Tax Court of Canada recently held, in Alta Energy Luxembourg SARL v R, 2018 TCC 152, that a Luxembourg S.A.R.L was entitled to treaty benefits on capital gains and that the general anti-avoidance [...]
2018 Tax Executives Institute
Speaking Engagements / April 12, 2018
Greg Johnson is a presenter at the 2018 Tax Executives Institute, Calgary Chapter Luncheon in Calgary, Alberta. Greg will share his insights on selected budget 2018 update, tax analysis of subscription receipts, reduction of treasury shares used to settle RSU obligations, note refinancings – 20(1)(c) issues and GAAR – subsequent legislative amendments.
2018 Energy Tax Symposium
Speaking Engagements / February 21, 2018
Greg Johnson is a panelist at the International Fiscal Association’s 2018 Energy Tax Symposium in Houston, Texas. Greg will share his insights on the energy challenges faced by Brazil, Canada and Mexico. Conference speakers include key energy tax experts from around the world.
Implication of Daishowa to Purchasers
Blog / January 19, 2018
Since the decision of the Supreme Court of Canada in Daishowa‑Marubeni International Ltd. v. Canada, 2013 SCC 29 [Daishowa], clarity exists for how a vendor treats abandonment obligations on the sale [...]
Schlumberger/Torxen Purchase Cenovus Assets
Announcements / October 18, 2017
On October 18, 2017, Schlumberger Production Management (SPM), along with Torxen Energy, entered into a definitive agreement for the purchase of the Palliser Block assets in Alberta from Cenovus Energy Inc., an integrated Canadian oil company, for cash consideration of $1.3 billion.
Budget 2017: Changes to Canadian Exploration Expense and Flow-Through Shares
Updates / March 24, 2017
Canadian exploration expenses (CEE) are certain types of expenses incurred by oil and gas, mining and renewable energy corporations. CEE is 100 percent deductible in the year the expense are incurred. Certain types of CEE also qualify for renunciation to investors under the flow-through share rules contained in the Act. With the exception of expenses related to the acquisition of Canadian resource property (which generally would be Canadian oil and gas property expense), most other oil and gas related expenses (other than tangible costs) qualify as Canadian development expenses (CDE). CDE is deductible at 30 percent on a declining balance basis. CDE can also be renounced under the flow-through share rules, but because of the reduced rate of deduction, is significantly less desirable for investors.
Canadian Tax Foundation Annual Conference (2016)
Speaking Engagements / November 27, 2016
Greg Johnson and Wes Novotny to present at the Canadian Tax Foundation 68th annual conference in Calgary: "An Update on Flow-through Shares in the Energy Sector" at Calgary, Alberta.
Canadian Petroleum Tax Society September Luncheon
Speaking Engagements / September 22, 2016
Greg Johnson and Wes Novotny presented at the Canadian Petroleum Tax Society (CPTS) September Luncheon on "Current Issues for Flow Through Shares" at Calgary, Alberta.
Dissenting Shareholders in Amalgamations
Articles / January 01, 2015
Jared A. Mackey & Greg Johnson, “Dissenting Shareholders in Amalgamations”, (January 2015) XIII(4) Corporate Structures & Groups (Federated Press) at 744.
Recent Resource Taxation Developments
Speaking Engagements / May 21, 2014
Greg Johnson and Wes Novotny present "Recent Resource Taxation Developments" at the Canadian Petroleum Tax Society in Calgary.
Canadian Bar Association Presentation(1)
Speaking Engagements / September 23, 2013
Greg Johnson presents, "First Nations Tax/Business Structuring," for the Canadian Bar Association in Calgary, AB.
Canadian Petroleum Tax Society Annual Meeting 2013
Speaking Engagements / June 11, 2013
Greg Johnson presents, "Forming U.S. Master Limited Partnerships with Canadian Assets: a U.S. and Canadian Perspective," at the Canadian Petroleum Tax Society Annual Meeting with Tim Devetski and Sidley Austin LLP.
Canada's Federal Budget Does Not Address Cross-Border Income Trusts
Updates / March 25, 2013
The March 2013 Federal Budget did not contain any provisions aimed at cross-border income trusts (CBITs, also known as foreign asset income trusts, or FAITs). Mention was made, however, of a continued intention to implement the specified investment flow-through (SIFT) related changes announced in 2011 and committed to draft legislation last summer, including those that shut down the use of stapled stock as a means to avoid the SIFT rules. Published on the Bennett Jones Thought Network.
Federated Press – Aboriginal Taxation Conference
Speaking Engagements / March 19, 2013
Greg Johnson presents, "First Nations Business Structure Options – Tax Implications," at the Federated Press – Aboriginal Taxation Conference in Calgary, AB.
64th Annual Tax Conference
In The News / November 25, 2012
Cathie Brayley and Darcy Moch are members of the planning committee for the Canadian Tax Foundation's (CTF) 64th Annual Conference in Calgary. On Day 1, Martin Sorensen leads the "Status Issues: Related Affiliated, and Associated" workshop and Darcy Moch speaks during the "CRA's Approach to Auditing" session. On Day 2, Robert McCue and Greg Johnson speak during the "Recent Transactions of Interest: Including a Discussion of Cross-Border Income Trusts" session and Anu Nijhawan is speaker during the "Update on Significant Employment Compensation Issues" session in the afternoon.
Cross Border Investment in Canada - Recent Amendments to the Definition of Taxable Canadian Property
Speaking Engagements / October 19, 2010
Greg Johnson and Wesley Novotny presented "Cross Border Investment in Canada - Recent Amendments to the Definition of Taxable Canadian Property" at the Canadian Tax Society Breakfast Speaker Series in Calgary, Alberta.
Incurring Flow-Through Share Expenditures
Articles / January 01, 2010
As a result of the frequent use of flow-through shares ("FTS") by small and medium size corporations, it is vital that certain common pitfalls are avoided. This article will review common issues surrounding FTS, specifically, the timing of incurring Canadian exploration expenditures ("CEEs") and Canadian development expenditures ("CDEs") (collectively, "Qualifying Expenditures"), the type of seismic data which may be renounced to FTS subscribers (the "FTS Holders" or the "FTS Holder"), and the classification of finite and infinite term seismic licenses. Written by Greg M. Johnson and Kyle Rousay; published in Resource Sector Taxation (Vol. VIII, No. 1, p. 555) by Federated Press.
Alberta Unlimited Liability Corporations
Updates / May 24, 2005
Amendments to the Alberta Business Corporations Act (ABCA) are in force as of May 17th, 2005. The most significant amendment to the ABCA is the ability to create unlimited liability corporations in Alberta. An Alberta unlimited liability corporation (ABULC) is, as the title suggests, a corporation whose shareholders have unlimited liability for any liability, act or default of the corporation.