Kennedy Claire

Education

University of Toronto, B.A.Sc., 1989 Queen's University, LLB, 1994 University of Chicago Booth School of Business, Advanced Management Program, 2019 University of Toronto, Doctor of Laws (honoris causa), 2023

Bar Admissions

Ontario, 1996

Claire M.C. Kennedy

Senior Advisor, Clients and Industries

T: 416.777.6150 / E: kennedyc@bennettjones.com

Toronto


As Senior Advisor, Clients and Industries, Claire Kennedy provides strategic advice, drawing on two decades of experience as one of Canada’s leading lawyers in tax and transfer pricing and as a seasoned corporate director.


Claire's director experience spans public company, Crown corporation and charity service, including as lead director of the Bank of Canada, the nation’s central bank. Claire's public company board experience includes service on companies listed on the TSX and NYSE. Currently, Claire is Chair of Neo Performance Materials Inc., a producer of rare earth products and metals essential for future facing technologies, and a director of Alamos Gold Inc., a North Americas focused gold producer and of Constellation Software Inc., a Canadian headquartered company that acquires and holds vertical market software (VMS) businesses.

Claire is a frequent speaker and moderator and moderates the presentation of the firm's flagship Economic Outlook report, authored by our Government Affairs and Public Policy group.

Claire received her ICD.D designation from the Institute of Corporate Directors and has completed the Making Corporate Boards More Effective program and the Advanced Corporate Director Seminar at Harvard Business School and the Advanced Management Program at the University of Chicago's Booth School of Business. She is also a professional engineer and she was law clerk to the late Honourable Mr. Justice Charles D. Gonthier of the Supreme Court of Canada.

Claire was appointed to the University of Toronto's Governing Council in 2012 and served as Chair from 2017 until the conclusion of her term in 2021. She is a member of the Dean's Advisory Committee at Rotman and is past president of the Engineering Alumni Association and founder of the Disrupters & Dilemmas Series (formerly Biz Skule™). Claire received an honorary Doctor of Laws from the University of Toronto in 2023. Claire is proud to co-chair the University of Toronto's Defy Gravity campaign.

In 2015, Claire received the Citizenship Award from the Professional Engineers of Ontario. In 2016, she participated in the True Patriot Love expedition to climb Vinson Massif, the highest peak in Antarctica, with a combined soldier and civilian team and raised record funds.

Select Experience

  • OrderDynamics Corporation, in its acquisition by TECSYS Inc.
  • Longview Aviation Capital Corp., in its acquisition of the Dash 8 program from Bombardier Inc.
  • SunEdison Canada in its CCAA proceedings, which together with the bankruptcy proceedings of its US parent, SunEdison Inc., represents one of the largest restructurings in the solar energy industry
  • Crocodile Gold Corp., (TSX) in its combination with Newmarket Gold Inc. (TSXV) pursuant to a court approved plan of arrangement for approximately $185 million
  • The Special Committee of Silver Bullion Trust, in its conversion to an Exchange Traded Fund in partnership with Purpose Investments Inc.
  • The Special Committee of Central GoldTrust, in Sprott Asset Management's $1-billion hostile takeover bid for all the outstanding Units of Central GoldTrust
  • The Special Committee of Silver Bullion Trust, in Sprott Asset Management's $62-million hostile takeover bid for all the outstanding Units of Silver Bullion Trust
  • SurfEasy Inc., in its acquisition by Opera Software
  • SunEdison DG Operating Holdings-2, LLC, in its acquisition of seven Ontario-based rooftop solar energy electricity generating projects
  • Glencore International, in its acquisition of all the outstanding shares of Viterra for approximately $6.1 billion by way of a plan of arrangement and the sale of certain assets of Viterra to each of Agrium and Richardson International for aggregate proceeds of approximately $2.6 billion
  • Xstrata Coal, in its $147-million acquisition of First Coal Corporation
  • Canadian counsel to a US-based international solar developer, with over 400 operational sites worldwide, including M&A transactions and groundmount and roofmount development projects
  • Sino-Forest Corporation, a commercial forest plantation operator in China formerly listed on the Toronto Stock Exchange, on all Canadian matters relating to or resulting from allegations that have been made against it and certain of its directors and officers since June, 2011. 
  • A pharmaceutical company in a transfer pricing matter
  • A U.S. based services company in a competent authority proceeding on a transfer pricing matter
  • Canadian based technology company in international tax and transfer pricing matters
  • Sociedad Punta del Cobre S.A.(Pucobre), a Chilean copper producer, in its proposed acquisition of Explorator Resources for $80 million by way of plan of arrangement
  • Synacor, Inc., in its acquisition of Carbyn
  • Blue Ant Media Inc., in its acquisition of Canadian broadcaster High Fidelity HDTV and its four premium high definition channels – Oasis HD, eqhd, radX and HIFI HD
  • Blue Ant Media Inc., in its acquisition of Canadian broadcaster GlassBOX Television Inc. and the Travel+Escape, Bite TV and AUX TV specialty channels
  • A U.S. headquartered retailer in the establishment of multiple business lines in Canada including transfer pricing of goods, services and IP
  • A foreign renewable energy developer on tax and transfer pricing matters, including aboriginal taxation, for Canadian projects
  • A U.S. based technology company on the acquisition of a Canadian software business
  • A U.S. based financial services firm on the acquisition of a Canadian business
  • A Canadian apparel distributor on the importation of goods and brand licensing from a related party
  • SMART Technologies Inc., in its initial public offering of 38,830,000 Class A Subordinate Voting Shares in the United States and Canada, for gross proceeds of US$660 million
  • Intrafinity Inc., doing business as SharpSchool, in the acquisition of substantially all of its assets by West Corporation

Recent Recognitions

  • Expert Guides

    EuroMoney, World's Leading Tax Lawyers
    Recognized as one of the world's leading Women in Business Law - Transfer Pricing
    Recognized as one of the world's leading Tax Advisers

  • Chambers Canada
    Tax

  • Chambers Global "The World's Leading Lawyers for Business"
    Canada, Tax

  • The Canadian Legal Lexpert Directory
    Repeatedly Recommended, Corporate Tax
  • Best Lawyers in Canada
    Recognized for Tax Law

  • International Tax Reviews Women in Tax Leaders
    Recognized as one of Canada's leading Women in Tax

  • Who's Who Legal: Canada
    Recognized as a leading lawyer in the area of Corporate Tax

  • Who's Who Legal: Corporate Tax
    Recognized as a leading lawyer: Advisory and Controversy
  • Who's Who Legal: The International Who's Who of Business Lawyers
    Recognized as a leading lawyer in the area of corporate tax

  • World Tax
    Ranked, Highly Regarded and Tax Leader, Women in Tax
    Recognized as an EG Tax Leading Advisor
  • World Transfer Pricing
    Ranked, Highly Regarded, Transfer Pricing

Recent Insights, News & Events

  • Bennett Jones Recognized in ITR World Tax 2025 Rankings
    Announcements / August 28, 2024
    Bennett Jones, along with eight Bennett Jones lawyers, have ranked in the 2025 edition of ITR World Tax, a comprehensive guide to the world's leading tax lawyers and firms.
  • Speaking the Truth About Productivity in Canada
    In The News / June 25, 2024
    David Crane writes in The Hill Times on the Bennett Jones' Mid-Year 2024 Economic Outlook and why Canadians must come to grips with the critical need to significantly improve our productivity and competitiveness.
  • 2024 Economic Outlook: The Long-Term Is Now
    Updates / December 11, 2023
    The global and Canadian economies are still adjusting to the shocks of COVID and war. Inflation remains elevated, and monetary conditions are restrictive. There are legacies, in particular high public and private debt. Concurrently, the forces of demographic ageing, climate change, and digitalization are intensifying in a new fragmented world, transforming our economies, and requiring more public and private investment. These two factors—short-term adjustment and structural change—set the background for our 2024 Economic Outlook.
  • Bennett Jones Ranks Tier 1 in ITR World Tax 2024
    Announcements / August 30, 2023
    Eight Bennett Jones lawyers are ranked in the 2024 edition of ITR World Tax, a comprehensive guide to the world's leading tax lawyers and firms.
  • 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.
  • Economic Outlook: Playing the Long Game
    Updates / June 12, 2023
    For the last three years, governments, businesses and workers have confronted a series of shocks and disruptions that have tested their agility and resilience. The pandemic, the war in Ukraine, supply chain constraints, swings in commodity prices, and higher inflation and interest rates, have demanded swift responses and adjustment. There are aftershocks, uncertainty and risk, and still a need to adapt. Navigating turbulent times remains a key function of policy and business planning. Yet, given forces shaping the world of tomorrow, it matters even more how governments and businesses plan to invest, innovate and create the conditions for sustainable growth over the longer term. This Economic Outlook entitled Playing the Long Game reviews recent developments and short-term prospects, sets out a baseline scenario and risks to assist business planning and describes some of the context for the longer term and key tasks ahead for Canadian governments and firms.
  • Special Events: Economic Outlook—Playing the Long Game
    Podcast / June 12, 2023
    This episode features insights into the short-term priorities to get Canada back on a path of non-inflationary growth and the longer term road ahead to closing the investment gap, increasing innovation and raising productivity growth. Looking beyond this horizon, the authors also discuss how governments and businesses can create the conditions to compete in a changing world and to grow the economy sustainably. Listen to our June 2023 Economic Outlook webinar, featuring former Bank of Canada Governor David Dodge and former Executive Director in the International Monetary Fund (IMF), Serge Dupont.
  • Bennett Jones Lawyers Recognized in ITR World Tax 2023
    Announcements / September 22, 2022
    Nine Bennett Jones lawyers are ranked in the 2023 edition of ITR World Tax, a comprehensive guide to the world's leading tax lawyers and firms.
  • Bennett Jones Spring 2022 Economic Outlook: Planning in an Uncertain, Supply-Constrained World
    Updates / June 16, 2022
    We present this Bennett Jones Spring 2022 Economic Outlook in a period of great uncertainty. A war in Europe and the ongoing COVID-19 pandemic, in addition to exerting a devastating human toll, have reverberated through the global and Canadian economies. How these and other external forces will evolve, and how policy authorities worldwide will respond, are unknowns that make the development of economic projections and business plans unusually hazardous.
  • Bennett Jones Fall 2021 Economic Outlook: Closing the Investment Gap
    Updates / December 08, 2021
    Economic activity and employment in Canada and in advanced economies continue to show a rapid, vigorous recovery. In a normal business cycle, businesses would now be stepping up plans to hire, to invest and to take advantage of the rebound of demand globally and domestically. To some extent, this is happening. In fact, employment in Canada has already regained its-pre-pandemic level. However, there are near-term uncertainties and pressures. The greatest uncertainty is the future evolution of the pandemic and its potential impact on the economy. There is public fatigue in continually adapting public health measures, the activity of daily life and the workplace to counter COVID and its variants. Yet, businesses have no choice but to be prepared for different scenarios in conducting and planning their activities.
  • Claire Kennedy Moderates Geopolitics of Supply Chains at CCBC AGM
    Speaking Engagements / October 27, 2021
    Claire Kennedy moderates the "Geopolitics of Supply Chains" panel session at the Canada China Business Council (CCBC) 43rd Annual General Meeting and Business Forum.
  • ESG and Institutional Investors: Part Two
    Blog / October 26, 2021
    Bennett Jones recently hosted a two-part webinar series on ESG and institutional investors. The first session looked at their role in ESG, private markets and investment, how risks and opportunities are being assessed in the boardroom, ESG performance in the energy industry and some predictions on what is ahead. The second session looked at ESG and pension plan administration with a focus on the issues at the interface of ESG and the duties of pension fiduciaries, as well as some predictions on what is ahead.
  • Canada and the Digitalization of Money
    Articles / October 21, 2021
    Canada and the Digitalization of Money is a report of a virtual conference of international and Canadian experts, organized by Bennett Jones and the Centre for International Governance Innovation (CIGI) and held on August 25, 2021.
  • ESG and Institutional Investors: Part One
    Blog / October 07, 2021
    Bennett Jones recently hosted a two-part webinar series on ESG and institutional investors. The first session looked at their role in ESG, private markets and investment, how risks and opportunities are being assessed in the boardroom, ESG performance in the energy industry and some predictions on what is ahead.
  • Bennett Jones' Transfer Pricing Leaders 2022
    Announcements / September 29, 2021
    Three Bennett Jones lawyers are ranked as Highly Regarded in the 2022 World Transfer Pricing guide.
  • Bennett Jones' World Tax Leaders 2022
    Announcements / September 29, 2021
    Eight Bennett Jones lawyers are ranked in World Tax, a comprehensive guide to the world's leading tax lawyers and firms. Bennett Jones is ranked as a firm in the practice areas: Tax, Tax Controversy and Transactional Tax.
  • ESG Institutional Investors' Series: Session 2
    Event / September 28, 2021
    The panel will consider how ESG considerations should be factored into decision-making by pension plan administrators or pension plan investment managers with regards to Canadian statutory requirements and the fiduciary duties of pension plan board and committee members. 
  • ESG Institutional Investors' Series: Session 1
    Event / September 22, 2021
    Please join us for a series of two engaging discussions focused on ESG for institutional investors and pension plan administrators and the companies with whom they invest and interact. 
  • 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.
  • Claire Kennedy Awarded the 2021 Meritorious Service Award
    Announcements / June 28, 2021
    Claire Kennedy is awarded the Meritorious Service Award for Community Service in the 2021 Engineers Canada Awards.
  • Claire Kennedy on "Overseeing a Small City" in U of T News
    In The News / June 22, 2021
    Claire Kennedy is featured in the University of Toronto's U of T News in "Overseeing a ‘small city’: Claire Kennedy reflects on her time as chair of U of T's Governing Council."
  • 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.
  • Transfer Pricing in the Time of COVID-19
    Articles / February 19, 2021
    Claire Kennedy and Hennadiy Kutsenko write in Canadian Accountant on recently released guidance from the OECD on COVID-19-impacted transfer pricing.
  • Supreme Court of Canada Declines to Hear the Cameco Landmark Transfer Pricing Case
    Blog / February 18, 2021
    On February 18, 2021, the Supreme Court of Canada announced that it will not hear the transfer pricing tax appeal involving the Government of Canada and Cameco Corporation. Cameco was previously successful in both the Tax Court of Canada and the Federal Court of Appeal. 
  • Transfer Pricing in the Time of COVID-19
    Blog / February 09, 2021
    Many Canadian businesses have closed the books on their 2020 fiscal year, having faced an unprecedented economic shock wrought by the pandemic. 2020 fiscal year results will undoubtedly be affected, in many cases to the downside, though positively for those businesses serving customers working and learning in a virtual environment and filling strong demand for PPE. As enterprises prepare 2020 income tax filings, there are special considerations for those multi-national enterprises (MNEs) subject to Canada's transfer pricing (TP) rules. In this Bennett Jones blog, we summarize recently released guidance from the Organization for Economic Development and Cooperation (OECD) on COVID-19 impacted TP, drawing attention to relevant statements by the Canada Revenue Agency (CRA).
  • Bennett Jones Fall 2020 Economic Outlook: Time for a Reboot
    Event / December 08, 2020
    The Outlook sets a context for businesses to plan by reviewing economic scenarios for the next two years and analyzing global and domestic policy factors that could shape the business environment in the years ahead.
  • Claire Kennedy Moderates Disruptors & Dilemmas – The View from 2025
    Speaking Engagements / November 10, 2020
    Claire Kennedy moderates a special edition of the U of T Faculty of Applied Science & Engineering’s Disruptors & Dilemmas speaker series. Bennett Jones is the presenting sponsor of this free virtual speaker panel.
  • Claire Kennedy on Dealing With Boardrooms at In-House Lawyers Summit
    Speaking Engagements / October 27, 2020
    Claire Kennedy speaks on a panel on Dealing with Boardrooms: Navigating the Dynamics and Politics of this Complex Relationship at the Canadian Lawyer In-House Lawyers Virtual Summit. The panel will look [...]
  • A USMCA Roundtable: The Perspective from Canada and Mexico
    Event / October 15, 2020
    Bennett Jones and Chevez Ruiz Zamarripa hosted a special webinar roundtable focused on understanding the USMCA and its impact from Canadian and Mexican perspectives, including new corporate compliance obligations and areas of risk.
  • Bennett Jones' Transfer Pricing Leaders 2021
    Announcements / October 02, 2020
    Three Bennett Jones partners are ranked as Highly Regarded in the 2021 World Transfer Pricing guide: Claire Kennedy Edwin Kroft Deborah Toaze World Transfer Pricing rates transfer pricing [...]
  • Bennett Jones Women in Tax Leaders 2021
    Announcements / October 02, 2020
    Three Bennett Jones partners are ranked as Highly Regarded in the 2021 Women in Tax Leaders guide, in association with the International Tax Review: Claire Kennedy (also ranked as a Tax Leader) [...]
  • Bennett Jones' World Tax Leaders 2021
    Announcements / October 02, 2020
    Eight Bennett Jones partners are ranked in World Tax, a comprehensive guide to the world's leading tax lawyers and firms: Stephen Bowman (Tax Leader) Thomas Bauer (Tax Leader) Jehad Haymour [...]
  • 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.
  • Canadian Accountant on Me Too Defeats You Too in Tax Court
    Articles / August 26, 2020
    Canadian Accountant features Claire Kennedy and Anu Nijhawan's blog on why the recent Tax Court of Canada case, Penate v. R., is welcome recognition that inequities faced by business owners who are subject [...]
  • Me Too Defeats You Too in Tax Court
    Blog / August 24, 2020
    The Me Too movement of the last few years and recent worldwide protests sparked by George Floyd's killing have focused welcome attention on combatting gender and racial discrimination and harassment. A recent Tax Court of Canada case, Penate v. R. [Penate], highlights that discrimination can be a relevant factor in assessing whether the Canada Revenue Agency (CRA) can hold a director liable for corporate tax delinquencies. In this unusual case, the Tax Court accepted that a female business owner could avoid vicarious ("you too") liability for her company's taxes because of ("me too") sexual harassment by customers that ultimately hurt the company's cash flow.
  • Bennett Jones Business Law Talks Podcast on Spotify and iTunes
    Announcements / July 09, 2020
    Bennett Jones'Business Law Talks podcast, A Way Forward: Energy Industry Ready to Fuel Canada's Recovery, is live on Spotify and the iTunes Store. This episode looks at why Canada must make the energy sector a driving force of our economic recovery from the COVID-19 pandemic.
  • Special Events: A Way Forward—Energy Industry Ready to Fuel Canada's Recovery
    Podcast / July 08, 2020
    Canada must make the energy sector a driving force of our economic recovery from the COVID-19 pandemic. Hear how we can do this while pursuing climate change goals, through transformative innovation and partnership between industry, governments and Indigenous communities. Claire Kennedy hosts this discussion with Vivek Warrier and Serge Dupont, all of Bennett Jones LLP.
  • Bennett Jones Spring 2020 Economic Outlook: Charting a Path for Canada
    Event / June 09, 2020
    The Outlook reviews the global economic context and the evolution of key economic and policy parameters for business planning. Following an analysis of the early impact of the COVID-19 crisis, the presentation describes scenarios for the global and Canadian economies over the next 18 months.
  • Managing the Tax Residency of Foreign Affiliates in the Face of the COVID-19 Restrictions
    Blog / May 25, 2020
    The COVID-19 pandemic has resulted in the imposition of travel restrictions by governments and businesses. While such restrictions are no doubt valuable in "flattening the curve", they do, amongst other things, pose challenges to Canadian multinational groups in maintaining the "mind and management" of foreign subsidiaries in the appropriate non-Canadian jurisdictions. The Canada Revenue Agency (CRA) has recently released helpful, although not definitive, guidance on certain tax residency issues resulting from such travel restrictions, which is generally consistent with guidance provided by other tax authorities worldwide.
  • 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. 
  • The Resilience and Agility of Women in Leadership
    Blog / November 04, 2019
    I recently moderated a panel of three inspiring women leaders from the Canadian Armed Forces (CAF), who spoke candidly about their career challenges and triumphs. The discussion was part of the second [...]
  • CTV News on True Patriot Love's Captain Nichola Goddard Reception
    In The News / October 30, 2019
    CTV News covered the second annual True Patriot Love Captain Nichola Goddard Reception held at Bennett Jones in Toronto.
  • Bennett Jones' Women in Tax Leaders 2020
    Announcements / October 01, 2019
    Three Bennett Jones partners are ranked as Highly Regarded Women in Tax Leaders by World Tax, in association with the International Tax Review
  • Bennett Jones' World Tax Leaders 2020
    Announcements / October 01, 2019
    Five Bennett Jones partners are ranked as Highly Regarded in World Tax, the comprehensive guide to the world's leading tax lawyers and firms.
  • Bennett Jones' World Transfer Pricing Leaders 2020
    Announcements / October 01, 2019
    Three Bennett Jones partners are ranked as Highly Regarded in World Transfer Pricing.
  • 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 [...]
  • 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. 
  • New GST/HST Rules Enacted for Fund Management Fee Arrangements
    Blog / January 09, 2019
    On December 13, 2018, legislation was passed implementing amendments to the Excise Tax Act (Canada) (the “ETA”) first announced in September 2017 affecting GST/HST on management and administrative [...]
  • Redefining Women in Leadership Through Canadian Values
    Blog / November 02, 2018
    Captain Nichola Goddard was the first female Canadian soldier to die in a combat role, while serving in Afghanistan. She was killed at age 26 during an ambush west of Kandahar city on May 17, 2006. Her [...]
  • Bennett Jones in Who’s Who Legal: Canada 2018
    Announcements / November 01, 2018
    64 Bennett Jones lawyers are ranked in 19 areas of Who’s Who Legal: Canada 2018. The guide identifies the foremost legal practitioners in multiple areas of business law for their annual publication.
  • The Canadian Senate to Review Bill C-21 for Enhanced Canada-U.S. Cross-Border Cooperation
    Blog / July 20, 2018
    On June 20, 2018, Bill C-21, An Act to amend the Customs Act was introduced in the Canadian Senate upon receiving third reading in the House of Commons. If enacted, the Bill will amend the Customs Act [...]
  • Bank of Canada Board of Directors
    Announcements / June 28, 2018
    Finance Minister Bill Morneau announced that Claire Kennedy has been reappointed to the Board of Directors of the Bank of Canada. Claire was first appointed to this role in December 2012.
  • Claire Kennedy and Lt Gen Christine Whitecross in The Lawyers Daily
    In The News / May 24, 2018
    The Lawyer’s Daily reports on Bennett Jones and True Patriot Love hosting Lt.-Gen. Christine Whitecross to hear her speak on leadership in the 21st century and what businesses can do to lead by example. Lt.-Gen. Whitecross is Canada’s highest ranking female military officer and the country’s first female three-star general. She is presently commandant of the NATO Defense College in Rome, the first female to hold this position. Claire spoke with Christine in a one-on-one talk and led a Q&A with the audience. Christine said that risk management, leadership and creating positive work environments are skills every law firm should incorporate into its practice, but in the age of cybersecurity and #MeToo it’s become even more apparent that legal workplaces need to step up efforts to deal with crises head-on.
  • IFA Canada - Recent Canadian Developments
    Speaking Engagements / May 15, 2018
    Claire Kennedy presents on "Recent Canadian Developments" at the International Fiscal Association's International Tax Conference 2018. 
  • Canadian Lieutenant-General Christine Whitecross on Leadership in the 21st Century
    Event / April 30, 2018
    Bennett Jones and True Patriot Love Foundation (TPL) invite you to hear from Lieutenant-General Christine Whitecross, Commandant of the NATO Defense College in Rome, on what it takes to lead strong and diverse teams through challenging and uncertain times. Lieutenant-General Whitecross is Canada’s highest ranking female military officer and first female three-star general. She was Chief of Military Personnel for the 60,000 men and women in uniform in the Canadian Armed Forces and was twice named one of Canada’s top 100 Most Powerful Women (2011 and 2016). True Patriot Love Foundation is a national charity dedicated to funding essential programs and services which support Canadian soldiers, Veterans and their families.
  • Claire Kennedy in Lexpert on Tax Reform and Cross-Border Commerce
    In The News / February 21, 2018
    Claire Kennedy comments in Lexpert on the U.S. enacting the most sweeping overhaul of the American tax system in more than 30 years—and what this could mean for Canada.
  • Claire Kennedy Appointed Managing Partner Clients and Industries
    Announcements / February 07, 2018
    Bennett Jones is pleased to announce that Claire Kennedy has been appointed Managing Partner, Clients and Industries of the firm. In her new role, she will work with the Vice Chair, Clients and Industries, leading and coordinating the firm’s industry groups and client initiatives.
  • Claire Kennedy on Key Tax Cases in Law Times
    In The News / January 29, 2018
    Claire Kennedy comments in a Law Times look at important Canadian corporate tax cases, which could see judgments as early as the first half of 2018. One is Oxford Properties Group Inc. v. The Queen 2016 TCC 204 (CanLII), which is in the Federal Court of Appeal and involves the contentious General Anti-Avoidance Rule of the Income Tax Act (GAAR). Claire says that as 2018 proceeds there will be a big focus on GAAR.
  • Claire Kennedy Helps Neo Performance Open TSX
    In The News / December 15, 2017
    Claire Kennedy and Neo Performance Materials Inc. opened the TSX today. Claire is on the company’s Board of Directors. Neo is a global leader in the innovation and manufacturing of rare earth and rare metal based functional materials. Neo Performance Materials Inc. commenced trading on Toronto Stock Exchange on December 8, 2017.
  • Queen's Law Congratulates Claire Kennedy on WXN Top 100
    In The News / December 08, 2017
    Queen’s Law Reports covers Claire Kennedy being named to the Top 100 list of Canada’s Most Powerful Women for 2017 by the Women’s Executive Network (WXN). Claire was asked what advice she would give women law students and junior lawyers for a successful legal career. Her response was to, “Seize opportunities when they present themselves even if you don’t think you are fully ready yet. Of course do your homework and prepare thoroughly but stretch assignments are just that – a stretch. Push yourself and you will be rewarded with a great sense of satisfaction and more importantly an opportunity to learn about yourself under pressure – as well as some new skills or domain expertise.”
  • Canadian Lawyer on Claire Kennedy: Canada's Most Powerful Women
    In The News / November 29, 2017
    Canadian Lawyer spoke with Claire Kennedy about being one of Canada’s Most Powerful Women in the Women’s Executive Network’s (WXN) Top 100 Awards for 2017. Claire commented on being a board director, her advice for future generations of women lawyers, and why women should “seize the opportunity when it arises. It may arise at a time when you think you’re not ready for it—if it’s interesting and rewarding, it’s probably a bit of a stretch assignment. You have to go for it. If it doesn’t give you a bit of a queasy feeling, you’re probably not pushing yourself hard enough.” The Lawyer’s Daily also covered Claire’s award.
  • Claire Kennedy One of Canada’s Most Powerful Women
    Announcements / November 22, 2017
    Bennett Jones congratulates Toronto partner Claire Kennedy on being named one of Canada’s Most Powerful Women in the Women’s Executive Network’s (WXN) Top 100 Awards for 2017.
  • Claire Kennedy and Anu Nijhawan ITRs Women in Tax Leaders
    Announcements / September 25, 2017
    Claire Kennedy and Anu Nijhawan are once again ranked in International Tax Review’s Women in Tax Leaders guide. The publication showcases the best women in tax from around the world and highlights the excellence of the industry’s top women.
  • Claire Kennedy in Bloomberg on Voluntary Disclosures Program
    In The News / June 14, 2017
    Claire Kennedy comments in Bloomberg BNA on the Canada Revenue Agency's proposal to limit its Voluntary Disclosures Program, including ending access to the program for transfer pricing cases and for corporations with gross revenues greater than C$250 million. Claire says that, if enacted, the proposed significant decrease in available benefits under the VDP means non-compliant taxpayers may be tempted to take their chances with an audit, thereby increasing the tax agency's enforcement costs and possibly reducing collections—both bad outcomes for the system.
  • No Appeal of BP Canada Decision on Working Papers, Announces CRA
    Blog / June 05, 2017
    The Canada Revenue Agency (CRA) has announced that it will not seek leave to appeal the Federal Court of Appeal's decision in the BP Canada case. This means that the Court's decision to deny the CRA general [...]
  • Claire Kennedy Begins Term as Chair of U of T's Governing Council on July 1
    Announcements / June 01, 2017
    The University of Toronto's Faculty of Applied Science & Engineering has announced that alumna Claire Kennedy will begin her term as Chair of the University's Governing Council on July 1, 2017. Claire was elected as Chair and the Governing Council oversees the academic, business and student affairs of the U of T.
  • Precedent on Claire Kennedy's True (Antarctic) Patriot Love
    In The News / May 30, 2017
    Precedent Magazine reports on Claire Kennedy's expedition up Mount Vinson with True Patriot Love, a group that funds and organizes programs for Canadian veterans. The mountain is the highest peak in Antarctica and one of the world's Seven Summits. Claire prepared for the climb by completing training in the Canadian Rockies and spending a year working out and taking long hikes with a weighted backpack. She personally raised $120,000 for True Patriot Love, more than twice her original goal. This Bay Street partner spent her holiday Antarctica’s highest mountain
  • Claire Kennedy on Cover of Lexpert on Tax Competition
    In The News / May 05, 2017
    Claire Kennedy is on cover of the April/May issue of Lexpert magazine. Claire comments in the feature story on "Tax Competition Returns" which looks at the impact heightened international tax competition would have on Canada. Claire says, “The UK has lowered taxes and we’re going to see tax reform of some kind in the U.S. as well. Any cut in the corporate tax rate in the U.S., whatever form it takes, will be a challenge because we’re a small, open economy that is very close geographically to the U.S. but has still managed to enjoy an economic advantage because of our lower corporate tax regime.”
  • Claire Kennedy and Philip Ward in ABA Tax Times
    In The News / May 03, 2017
    Claire Kennedy and Philip Ward in ABA Tax Times wrote on the Canadian Federal Court of Appeal decision in BP Canada Energy Company v. MNR in the American Bar Association's Tax Times. The decision reversed the judgment of the lower court and held that the CRA is not entitled to routinely demand access to taxpayers’ tax accrual working papers in the course of an audit.
  • Claire Kennedy to Co-Chair IFA Canadian Branch Spring Seminar
    Speaking Engagements / April 25, 2017
    Claire Kennedy to co-chair IFA Canadian Branch Spring Seminar April 25-26, 2017.
  • On the Ice with Artificial Intelligence
    Blog / April 21, 2017
    Taking Wayne Gretzky's famous advice—"skate to where the puck is going, not where it has been"—will get easier for businesses that embrace artificial intelligence (AI). That's the conclusion I drew from [...]
  • No Routine Access by CRA to Tax Working Papers Rules the Federal Court of Appeal
    Blog / April 05, 2017
    The Federal Court of Appeal has limited the Canada Revenue Agency's (CRA) access to tax accrual working papers that reveal a taxpayer's uncertain tax positions. This case is an important one for every [...]
  • Four Bennett Jones Practices Ranked Band 1 by Chambers Global 2017
    Announcements / March 16, 2017
    The 2017 Chambers Global Rankings are out and Bennett Jones is once again noted as a top-ranked law firm. Forty-nine lawyers in 25 practice areas are recognized in the publication. Of particular note are the four practices and nine lawyers recognized in Band 1.
  • International Compliance Professional Association EU Conference 2017
    Speaking Engagements / March 12, 2017
    Darrel Pearson and Claire Kennedy recently attended the International Compliance Professional Association's (ICPA) EU Conference in Miami, Florida from March 12-15, 2017.  Attached is the power point presentation they jointly presented with Christina Rinne of Neiderer Kraft & Frey Ltd. on March 14th entitled: "Impact of BEPS from a Customs and VAT Perspective".
  • Rio Tinto Alcan v. The Queen: Welcome Expansion of the Canadian Tax Deductibility of M&A Transaction Expenses
    Articles / February 17, 2017
    In a welcome decision for Canadian acquirors and targets, the Tax Court of Canada recognized, in Rio Tinto Alcan Inc. v The Queen, that certain oversight expenses—including certain investment banking and other professional advisory fees—should be deductible in the context of M&A transactions. This is particularly so where such services are provided to enable the board of directors of the acquiror or target to determine whether to proceed with the transaction. The Court also established a principled basis for the deductibility of transaction expenses in a far broader set of circumstances than those previously accepted by the Canada Revenue Agency (the CRA), in particular, in situations in which a board is discharging its oversight function prior to a decision to implement a particular transaction(s). The decision is under appeal; if affirmed, it will represent a significant expansion of the deductibility of transaction fees. The onus will remain on the taxpayer to prove the expenses are deductible based on the new criteria; engagement letters for advisors and their invoices, clearly demarcating oversight activities in respect of proposed transaction(s) from the implementation phases, should be prepared accordingly. C. Kennedy and A. Nijhawan, "Rio Tinto Alcan v. The Queen: Welcome Expansion of the Canadian Tax Deductibility of M&A Transaction Expenses" Vol 36 No. 2 (February 2017) ABA Tax Times (American Bar Association, 2017).
  • Is Your Customs Compliance BEPS Ready?
    Blog / February 08, 2017
    2016 was the first year of the new transfer pricing reporting regime called Country-by-Country Reporting (CbCR). It will be a major new tool for revenue authorities and will undoubtedly lead to greater [...]
  • Claire Kennedy in Bloomberg on Transfer Pricing and Voluntary Disclosure
    In The News / December 13, 2016
    Claire Kennedy comments in Bloomberg BNA on the Offshore Compliance Advisory Committee's report on the Canada Revenue Agency’s Voluntary Disclosures Program. Claire says the recommendations by the "credible, knowledgeable" panel for significant restrictions on voluntary disclosure represent a "fair and balanced" approach.
  • What Trump's Tax Plan Means For Canada
    Blog / November 15, 2016
    The election of Donald Trump combined with Republican control of Congress means that U.S. tax reform has suddenly gone from totally impossible to highly likely. The specifics of that reform are not known [...]
  • Tax Uncertainty Hinders Global Growth: Business Survey Launched
    Blog / October 25, 2016
    Businesses are invited to participate in an international survey from the CD to measure the impact of tax uncertainty on their investment decisions. Companies have until December 16 to participate in [...]
  • Tax Court Allows Deduction for Advisory Fees in M&A Transaction
    Blog / July 22, 2016
    The Tax Court of Canada has recognized in a recent case that "oversight expenses" "notably investment banking and other professional advisory fees for services rendered to boards of directors in their [...]
  • Claire Kennedy in Bloomberg: CIT Interest Income Case in Canada Tax Court
    In The News / July 22, 2016
    Claire Kennedy comments in Bloomberg BNA on the CRA's aggressive pursuit in taxing CIT Group Securities (Canada) Inc. on interest income earned by its affiliates in Barbados. The Tax Court of Canada ruled in CIT's favour. The CRA was criticized for dedicating scarce resources to pursue a case which was obviously weak. CIT clearly operates as a lender in Barbados and in the US.
  • Claire Kennedy in Bloomberg on Rio Tinto Canada Tax Case
    In The News / July 22, 2016
    Claire Kennedy comments in Bloomberg BNA on the Tax Court of Canada ruling that Rio Tinto Alcan Inc. can deduct C$51.6 million in legal, banking and regulatory costs used to acquire a competitor and to spin off a business unit. Claire said the ruling provides welcome clarity on the age-old question of income versus capital in the context of merger and acquisition transactions under evolved and evolving standards of corporate governance.
  • Claire Kennedy and Robert McCue on the BEPS Effect
    In The News / June 15, 2016
    Claire Kennedy and Robert McCue comment in Lexpert on the impact of the Canadian government’s fight against base erosion and profit shifting. The story appeared in Lexpert's 2016 Guide to the Leading US/Canada Cross-Border Corporate Lawyers in Canada.
  • University of Toronto on Claire Kennedy's True Patriot Love
    In The News / March 23, 2016
    U of T Engineering News reports on Claire Kennedy's expedition to one of the world's Seven Summits for the well-being of Canadian soldiers. In January 2016, Claire journeyed to Vinson Massif, the highest peak in Antarctica, as part of True Patriot Love Foundation's signature expedition in 2016. Eight ill and injured soldiers and 17 Canadian business leaders took part. The trip exceeded its fundraising goal of $1 million for TPL. Claire personally raised over $109,000, more than twice her original goal.
  • Claire Kennedy in Bloomberg on Transfer Pricing and Tax Breaks
    In The News / March 22, 2016
    Claire Kennedy comments in Bloomberg *BNA's Transfer Pricing Report™ on how the CRA has advised that Canadian companies that receive government assistance can't use those benefits to reduce the costs of goods or service provided to foreign affiliates—unless they can show that unrelated parties would do so. *Reproduced with permission from Tax Management Transfer Pricing Report, 24 Transfer Pricing Report (Mar. 31, 2016). Copyright 2016 by The Bureau of National Affairs, Inc. (800-372-1033) 
  • Claire Kennedy on Cover of The Lawyers Weekly: Antarctic Expedition
    In The News / February 22, 2016
    Claire Kennedy appears on the cover of The Lawyers Weekly in a feature story on her expedition to Vinson Massif—the highest peak in Antarctica and one of the world's Seven Summits. Claire was part of True Patriot Love (TPL) Foundation's signature fundraising expedition in 2016.
  • National Post: Claire Kennedy Braves Antarctic Peak in Support of Mental Health
    In The News / February 17, 2016
    The National Post reported on Claire Kennedy's Antarctic expedition to Vinson Massif—the continent's highest peak and one of the world's Seven Summits. Claire was part of True Patriot Love Foundation's (TPL) signature expedition in 2016, where 8 ill and injured soldiers and 17 Canadian business leaders took part. The journey exceeded its fundraising goal of $1 million for TPL. Claire personally raised over $119,000, well over twice her original goal. Bennett Jones is TPL's pro bono counsel.
  • International Tax Planning For Canadians in a World of Changing Rules
    Speaking Engagements / February 09, 2016
    Claire Kennedy was a panellist on the topic "October 2015 CD Final BEPS Reports – The Readers Digest Version" at the Toronto International Tax Planning for Canadians in a World of Changes Rules conference.
  • Bennett Jones' Claire Kennedy and True Patriot Love in Antarctica
    Announcements / February 01, 2016
    Bennett Jones' tax partner, Claire Kennedy, has just returned from Antarctica on an expedition to Vinson Massif—the highest peak in Antarctica at 16,050 feet and one of the world's Seven Summits. Claire was part of True Patriot Love (TPL) Foundation's signature expedition in 2016, where eight ill and injured soldiers and 17 Canadian business leaders took part.
  • Claire Kennedy in Bloomberg on Transfer Pricing in Canada
    In The News / January 12, 2016
    Claire Kennedy comments in Bloomberg BNA's Transfer Pricing Report on the Canada Revenue Agency continuing to enhance its approach to transfer pricing in 2016. Claire also sees the implementation of the CD's Base Erosion and Profit Shifting (BEPS) as a key tax story to watch in Canada in 2016.
  • Ontario Society of Professional Engineers' WEAC Fall Forum
    Speaking Engagements / November 28, 2015
    At the WEAC Fall Forum in Toronto, Claire Kennedy is a panelist during the session "First Hand Stories from Women Engineers on Boards".
  • Claire Kennedy joins Executive of IFA Canadian Branch
    Announcements / November 01, 2015
    Claire Kennedy joins Executive of IFA Canadian branch.
  • Key Policy Initiatives from Canada's New Liberal Government You Need to Anticipate
    Updates / October 26, 2015
    The Canadian election last week (October 19) produced a new government under Liberal Party leader Justin Trudeau. Defying speculation of a minority government, the Liberals won a clear majority, defeating the NDP and Stephen Harper's Conservative government to mark a decisive return to a centre-left government in Canada.
  • IBA Vienna
    Speaking Engagements / October 01, 2015
    Claire Kennedy was a Speaker/Panelist "Joint Ventures and Strategic Alliances".
  • Claire Kennedy Wins Ontario Professional Engineers Award
    Announcements / July 13, 2015
    In a release, the Ontario Society of Professional Engineers (OSPE) and Professional Engineers Ontario (PEO) announced the winners of the 2015 Ontario Professional Engineers Awards (OPEA), which will be presented at the annual OPEA Gala on Saturday, November 21, 2015. Bennett Jones' Claire Kennedy will receive the Professional Engineers Citizenship Award. Since 1947, the OPEAs have recognized professional engineers in Ontario who have made outstanding contributions to their profession and community.
  • Bermuda Executive Forum 2015 on Bermuda E-commerce
    Speaking Engagements / May 06, 2015
    Claire Kennedy and Duncan Card speak at the Bermuda Executive Forum 2015 on Bermuda E-commerce on May 6, 2015 in Calgary.
  • Bermuda CFO Forum 2015 on Bermuda Captives
    Speaking Engagements / May 05, 2015
    Claire Kennedy speaks at the Bermuda CFO Forum 2015 on Bermuda Captives on May 5th in Toronto and May 6th in Calgary.
  • Bennett Jones Receives Top Honours in Four Practice Areas by Chambers Global Rankings
    Announcements / March 18, 2015
    The 2015 Chambers Global Rankings have been published and once again Bennett Jones LLP remains one of the top ranked law firms in the country, with 18 rankings out of 28 categories and 60 individually ranked lawyers.
  • CRA Releases Important Transfer Pricing Guidance on Management Fees and Other Intra-Group Services
    Blog / February 24, 2015
    CRA recently released a new Transfer Pricing Memorandum (TPM-15) giving detailed guidance on CRA's audit approach to management fees and other charges for intra-group services, including on allocation [...]
  • Claire Kennedy in Tax Notes International on CRA Transfer Pricing
    In The News / February 23, 2015
    In the Tax Notes International article, "Guidance Targets Intragroup Services and Multiple-Year Data", Claire Kennedy comments on the Transfer Pricing Memorandum (TPM-15) released by the Canada Revenue Agency on management fees and other charges for intra-group services.
  • CTF/IFA BEPS Symposium, 2015
    Speaking Engagements / February 10, 2015
    Claire Kennedy presents at the Canadian Tax Foundation/International Fiscal Association Canadian BEPS Symposium on Transfer Pricing in Toronto, Ontario and Calgary, Alberta.
  • Darrel Pearson and Claire Kennedy Blog on Import Duty Refunds Quoted
    In The News / January 20, 2015
    In the Financial Post article by Julius Melnitzer, "CBSA Reverses Three-decade-old Import Duty Refund Policy", the Bennett Jones Thought Network post written by Darrel Pearson and Claire Kennedy is noted for describing the new policy by the Canada Border Services Agency.
  • Canadian Customs Authority Shifts Gears on Import Duty Refunds
    Blog / January 19, 2015
    The CBSA has made a long-sought-for change in its policy to allow duty refunds in the event of qualifying downward transfer price adjustments by importers. The change comes on the heels of victory by [...]
  • Canadian Importers May Now Seek Import Duty Refunds
    Updates / January 19, 2015
    Since the introduction of the Transaction Value System of customs valuation by Canada on January 1, 1985, the Canada Border Services Agency (CBSA) has maintained a stated policy of denying refund claims of related party importers who seek to amend declared values for duty to account for adjustments that decrease transfer prices after importation. The CBSA's interpretive proposition that value for duty reduction is precluded is based on its statutory exclusion as "rebates or decreases in the price paid or payable effected after goods are imported." In contrast, if transfer prices are adjusted such that they are increased after importation, Canadian importers face the compliance obligation to amend entries and pay additional duties and taxes as applicable. Bending under the pressure of adverse findings by the Canadian International Trade Tribunal (CITT) and the Federal Court, the CBSA has corrected this imbalance by effecting a major change in policy. Subject to meeting evidentiary requirements, Canadian importers may now seek refunds of customs duties in cases where transfer prices are adjusted downward after importation if the adjusted prices paid or payable were the subject of an agreement in writing at or prior to importation.
  • Claire Kennedy in the Financial Post on GlaxoSmithKline Settlement
    In The News / January 12, 2015
    In the Financial Post article by Julius Melnitzer, "GlaxoSmithKline Transfer Pricing Case Settled", Claire Kennedy comments on the significance of GlaxoSmithKline settling its dispute with the Canada Revenue Agency.
  • Claire Kennedy in Canadian Lawyer on Tax Lawyer
    In The News / January 05, 2015
    In the Canadian Lawyer article by Jennifer Brown, "Tax Guy to the Rescue", Claire Kennedy comments on the growing role of tax lawyers in the risk management planning of public and private companies.
  • BEPS Tail Shouldn't Wag Global Investment Dog
    Blog / November 17, 2014
    I spoke recently on a panel in Tokyo on the future of international tax planning after BEPS (the CD's & G20's Action Plan to counter Base Erosion & Profit Shifting). The panel also featured a senior official [...]
  • Tax Controversy - 2015
    Articles / October 28, 2014
    Published in Getting the Deal Through – Tax Controversy 2015, Claire Kennedy and Martin Sorensen present the Canadian chapter of this international guide outlining key aspects of income tax dispute resolution.
  • BC LNG Tax Regime: Rate Concessions and New Tax Credit but Uncertainty Remains
    Updates / October 24, 2014
    On October 21, 2014, the British Columbia government introduced Bill 6, the Liquefied Natural Gas Income Tax Act (LNGITA). Bill 6 is the legislative framework for the tax regime announced in the 2014 British Columbia budget. The LNGITA has important implications for the development of LNG facilities in British Columbia and its owners, operators and customers. The regime proposes a two-tier tax on income derived from liquefaction activities at liquefied natural gas (LNG) facilities in British Columbia starting in 2017. The regime applies a 1.5-percent tax on net income (as defined for LNG tax purposes) prior to the recovery of operating losses and capital investments and a 3.5-percent tax on net income (increasing to five percent in 2037) after recovery of those costs, with a credit for taxes paid in the first bracket. These rates represent a decrease from the seven-percent tax rate proposed in the 2014 British Columbia budget, which together with a new corporate income tax credit for qualifying taxpayers, appear to be a concession by the government that the originally proposed tax was too costly given the investment risks for project developers. Nonetheless, considerable uncertainty in the application of the tax remains, especially in the calculation of net income based on deemed purchase and sale rules using transfer pricing principles and careful consideration of these will be required.
  • International Fiscal Association 2014 Congress
    Speaking Engagements / October 12, 2014
    Claire Kennedy speaks on a panel with a CD senior official in "Life After BEPS: Is There Anything Left in International Tax Planning?"
  • Transfer Pricing: Strategies to Minimize Customs and Tax Risks to Your Business
    Speaking Engagements / October 08, 2014
    In cooperation with Thomson Ahern International, Claire Kennedy and Darrel Pearson present, "Transfer Pricing: Customs and Tax", during the webinar Transfer Pricing: Strategies to Minimize Customs and Tax Risks to Your Business. Darrel's presentation focuses on Convergence and non-Convergence of Transfer Pricing Principles; Developing a Unified Approach; Key Issues in Transfer Pricing/Customs Valuation (multiple subject goods, intellectual property, services); Contemporaneous Documentation for CRA and CBSA; Transfer Pricing Adjustments; Voluntary Disclosures; and Enforcement Trends. A recording of the webinar can be viewed by following this link (registration required).
  • Judicial Review Application Preserved in Transfer Pricing Penalty Case
    Blog / October 01, 2014
    A recent Federal Court of Appeal (FCA) case illustrates how contentious transfer pricing disputes can be - even one a taxpayer believed had been resolved! It also represents a rare situation in which [...]
  • Revised CRA Policy Heralds Focus on Contemporaneous Transfer Pricing Documentation
    Blog / July 07, 2014
    CRA released an updated transfer pricing memorandum, TPM-05R, Requests for Contemporaneous Documentation, in March, which describes the procedural aspects of transfer pricing documentation requirements [...]
  • Tax Effective Use by Canadian Online Retailers of Bermuda Operations for International Expansion
    Updates / June 10, 2014
    The growth of online retail sales has globally outstripped the growth of all other retail channels, including during the last recession. For example, in England during 2012, it has been estimated that online e-tail grew by an average of 17 percent, compared to all other retail growth in England of approximately 2.1 percent during the same period. In 2012, Canadian companies sold $122 billion of goods and services over the Internet, and in 2012, 11 percent of Canadian firms sold their goods and services online, compared to only seven percent in 2011. In the U.S., there are 263 million Internet users and more than 100 million Americans regularly purchasing goods online. Forbes estimates that by 2017, U.S. online retail sales will reach $370 billion.
  • 2014 IFA International Tax Seminar
    Speaking Engagements / May 22, 2014
    Claire Kennedy co-moderates the Government Roundtable, featuring representatives of the IRS and the CRA, at IFA's Joint Canada – U.S. Branch International Tax Seminar in Toronto, Ontario.
  • Claire Kennedy in Law Times on Tax Adviser Penalties
    In The News / April 14, 2014
    In the Law Times article by Julius Melnitzer, "SCC Consideration of Adviser Penalties Significant For Lawyers", Claire Kennedy comments on the adviser penalties in the Income Tax Act that are being reviewed by the Supreme Court of Canada.
  • Claire Kennedy in Lexpert on CD's BEPS Action Plan
    In The News / March 01, 2014
    In the Lexpert article, "Targeting Tax", Claire Kennedy comments on the Organization for Economic Co-operation and Development's new action plan on BEPS (Base Erosion Profit Sharing). The suggested modifications target multinational companies using tax planning strategies that exploit gaps or mismatched tax rules in order to reduce their tax burden.
  • Businesses Face More Onerous Transfer Pricing Documentation and Country-by-Country Tax Reporting
    Blog / February 27, 2014
    The CD proposes to reform transfer pricing documentation for multinational enterprises and to impose onerous country-by-country (CbC) reporting obligations, including disclosure of taxes paid in each [...]
  • IBA Taxes Committee – Submission to the CD on Transfer Pricing Documentation & Country-by-Country Reporting
    Articles / February 21, 2014
    Claire Kennedy co-authors the IBA Taxes Committee Submission to the CD on the proposed discussion draft on new standards for Transfer Pricing Documentation and Country-by-Country reporting requirements.
  • McKesson: A Cautionary Transfer Pricing Tale
    Articles / February 01, 2014
    Brad Rolph of Grant Thornton and Claire Kennedy of Bennett Jones review the decision of the Tax Court of Canada in McKesson Canada Corporation v HM The Queen, describe approaches to pricing factoring arrangements and highlight some of the key lessons for multinationals from this case. Published in the February 2014 edition of International Tax Review.
  • Claire Kennedy in the Ottawa Citizen on Crowdfunding Websites
    In The News / January 31, 2014
    In the Ottawa Citizen article by Vito Pilieci, "Chive Nation Ottawa a Leader in Evolving World of Online Charity Fundraising", Claire Kennedy comments on tax issues for money raised through crowdfunding websites.
  • Taxpayer Loses Canadian Transfer Pricing Case
    Blog / January 22, 2014
    A recent transfer pricing case from the Tax Court of Canada (McKesson Canada Corporation v The Queen) establishes a broad interpretation of the "regular" (non-recharacterization) transfer pricing rule [...]
  • Claire Kennedy Discusses Transfer Pricing in Worldwide Tax Daily
    In The News / January 21, 2014
    In Kristen A. Parillo's article in Worldwide Tax Daily (2013 WTD 139-7), "Lessons on Double Taxation Under the Canada-U.S. Tax Treaty", Claire Kennedy discusses the Federal Court of Canada's May 29 decision in TeleTech Canada, Inc. v Minister of National Revenue, in which the Canadian taxpayer was unable to compel CRA to participate in Competent Authority negotiations with the US to relieve double tax in a transfer pricing matter stating "it's a cautionary tale for taxpayers that you can't expect to get effective procedural relief through the judicial review process on the basis of the larger equities in the case."
  • The Knowledge Group's Transfer Pricing: Avoiding Financial Risks and Dealing with Tax Consequences
    Speaking Engagements / December 16, 2013
    Claire Kennedy and Darrel Pearson speak at the Knowledge Group's live webcast, "Transfer Pricing: Avoiding Financial Risks and Dealing with Tax Consequences".
  • Supreme Court Endorses Key Tax Principle: Tax Law Should Follow Private Law Agreements
    Blog / December 11, 2013
    The Supreme Court of Canada recently endorsed a fundamental principle in Canadian tax law "namely that absent sham or statutory recharacterization rules", "tax law applies to transactions governed by, [...]
  • International Bar Association Tax Conference 2013
    Speaking Engagements / November 22, 2013
    Claire Kennedy co-chairs the panel, "Rethinking International Taxation As We Know It: What Senior Practitioners Should Learn From Younger Ones".
  • IBA Taxes Committee – Submission to the CD on Intangibles
    Articles / October 01, 2013
    Claire Kennedy co-authors the IBA Taxes Committee Submission to the CD on the July 30, 2013 discussion draft on Intangibles Transfer Pricing.
  • Tax Controversy 2014
    Articles / July 29, 2013
    Published in Getting the Deal Through – Tax Controversy 2014, Claire Kennedy and Martin Sorensen present the Canadian chapter of this international guide outlining key aspects of income tax dispute resolution.
  • CD Launches Action Plan on Base Erosion and Profit Shifting
    Blog / July 23, 2013
    The CD released its Action Plan on Base Erosion and Profit Shifting (BEPS) on Friday. The BEPS initiative was launched earlier this year at the request of the G20 to counter alleged abuses by multinational [...]
  • Claire Kennedy Interviewed on TeleTech Case by Worldwide Tax Daily
    In The News / July 19, 2013
    In Kristen Parillo's Worldwide Tax Daily article, "News Analysis: Lessons on Double Taxation Under the Canada-U.S. Treaty", Claire Kennedy comments on TeleTech Canada, Inc. v. Minister of National Revenue (2013 FC 572), a Canadian transfer pricing case involving Canadian competent authority procedures.
  • Claire Kennedy in the Financial Post on CRA's New Audit Policy for Tax Shelters
    In The News / July 10, 2013
    In the Financial Post article by Julius Melnitzer, "Court Smacks Down Tax Crackdown", Claire Kennedy comments on criticism by the Federal Court that a new Canadian Revenue Agency audit policy discourages taxpayers from participating in tax shelters.
  • CD Revising Intangibles Transfer Pricing Discussion Draft
    Blog / June 10, 2013
    At the CD International Tax Conference in DC on June 3 and 4, J Andrus, Head of the CD's Transfer Pricing Unit, announced that the CD's Discussion Draft on Intangibles released in 2012 is under revision [...]
  • 2013 IFA International Tax Seminar
    Speaking Engagements / May 23, 2013
    Claire Kennedy moderates the Canada Revenue Agency Roundtable at IFA's Canadian Branch International Tax Seminar in Montreal, Quebec.
  • Substantive Series: Transfer Pricing - Recent Developments Businesses Need to Know
    Bennett Jones Academy Events / May 09, 2013
    Join Bennett Jones and our experienced panel for a discussion which will focus on transfer pricing; the GlaxoSmithKline case; the Jockey Canada case; and strategies for dispute resolution.
  • GlaxoSmithKline Case: Legal Form and Economic Relevance Prevail
    Articles / April 02, 2013
    The Glaxo decision is a positive one for businesses; however, the Supreme Court of Canada (SCC) has sent a clear signal that the transfer pricing policy established for each related party transaction matters and the transfer prices in the case of multiple transactions, such as the licence of a trademark and the supply of both goods and services, will be carefully scrutinized, argue Claire M. C. Kennedy of Bennett Jones and Brad Rolph, president of Transfer Pricing Specialists. Published in the April 2013 edition of International Tax Review.
  • International Tax & Transfer Pricing Strategies in the Crosshairs
    Blog / February 21, 2013
    The CD recently issued a report targeting corporate tax planning and transfer pricing strategies, which it asserts constitute a serious risk to tax revenues, tax sovereignty among nations and tax fairness. [...]
  • International Tax & Transfer Pricing Strategies in the Crosshairs
    Updates / February 21, 2013
    The CD recently issued a report targeting corporate tax planning and transfer pricing strategies, which it asserts constitute a serious risk to tax revenues, tax sovereignty among nations and tax fairness. (CD (2013), Addressing Base Erosion and Profit Shifting, CD Publishing) Published on the Bennett Jones Thought Network.
  • Claire Kennedy in the Financial Post on Tax Court of Canada Decision
    In The News / February 13, 2013
    In the Financial Post article by Julius Melnitzer, "Tax Court Forces Canada Revenue Agency to Expand Disclosure", Claire Kennedy comments on the recent decision by the Tax Court of Canada that will require the Canada Revenue Agency to provide greater disclosure when litigating under the general anti-avoidance rule (GAAR) of the Income Tax Act.
  • Marketing Intangibles in International Transfer Pricing
    Blog / January 29, 2013
    An Indian tax appellate tribunal has recently ruled on the issue of marketing intangibles in a transfer pricing case involving the Indian manufacturing and sales subsidiary of the Korea-based LG Electronics [...]
  • Marketing Intangibles in International Transfer Pricing
    Updates / January 29, 2013
    An Indian tax appellate tribunal has recently ruled on the issue of marketing intangibles in a transfer pricing case involving the Indian manufacturing and sales subsidiary of the Korea-based LG Electronics Inc. Published on the Bennett Jones Thought Network.
  • Claire Kennedy Comments in Lexpert on GlaxoSmithKline Transfer Pricing Case
    In The News / January 09, 2013
    In the Lexpert article by Julius Melnitzer, "The Business of the Courts", Claire Kennedy comments on the Canada v. GlaxoSmithKline transfer pricing case decision by the Supreme Court of Canada that Lexpert ranked as 2nd in its Top 10 Cases of 2012. 
  • Claire Kennedy in the Financial Post for Bank of Canada Appointment
    In The News / December 19, 2012
    In the Financial Post article by Julius Melnitzer, "Bennett Jones Partner Appointed to Bank of Canada Board", Claire Kennedy is recognized for her appointment to the Bank of Canada's Board of Directors. 
  • Claire Kennedy Appointed to Bank of Canada Board of Directors
    Announcements / December 18, 2012
    Canada's Minister of Finance, Jim Flaherty, announced today the appointment of Claire Kennedy to the Bank of Canada's Board of Directors. 
  • Claire Kennedy in the Litigation Daily on GlaxoSmithKline Transfer-Pricing Case
    In The News / December 14, 2012
    In the Litigation Daily article by Julie Triedman, "Supreme Court of Canada Rules for GlaxoSmithKline in Transfer-Pricing Case", Claire Kennedy comments on the Supreme Court decision that the Canadian government had to take into account more than just the narrow market price of a product when assessing whether GlaxoSmithKline's transfer pricing was reasonable. 
  • Supreme Court of Canada Establishes Important Principles in Transfer Pricing
    Blog / December 03, 2012
    The Supreme Court of Canada recently released its judgment in The Queen v Glaxo Smith Kline Inc., (Glaxo), which is the Court's first pronouncement on Canada's transfer pricing rules. Transfer pricing [...]
  • Supreme Court of Canada Establishes Important Principles in Transfer Pricing
    Updates / December 03, 2012
    The Supreme Court of Canada recently released its judgment in The Queen v Glaxo Smith Kline Inc., (Glaxo), which is the Court's first pronouncement on Canada's transfer pricing rules. Transfer pricing involves the allocation of profits in cross-border transactions among related parties and it is a contentious issue that can result in double taxation for taxpayers as governments in different jurisdictions seek to tax the same income. Transfer pricing is a high priority enforcement area for the Canada Revenue Agency and revenue authorities in other countries. Although the Glaxo case involved the interpretation of an earlier iteration of Canada's transfer pricing rules, the Supreme Court's reasons establish some key principles that should have application to Canada's current transfer pricing regime and the case is therefore an important one for Canadian multi-nationals. Overall, the decision is a positive one for Canadian businesses; however, the Supreme Court has sent a clear signal that allocation of transfer prices among related parties participating in multiple transactions, such as the licence of a trademark and the supply of goods and/or services, will be carefully scrutinized. Multiple transaction arrangements are common amongst multi-national enterprises large and small and, in light of the Glaxo case, businesses should revisit their transfer pricing documentation and legal agreements to mitigate the risk of reassessment and penalties by tax and customs authorities. 
  • Claire Kennedy Joins the Council of the Canadian Branch of the International Fiscal Association (IFA)
    Announcements / November 26, 2012
    Claire Kennedy welcomed to the Council of the Canadian branch of the International Fiscal Association (IFA). The IFA is the only non-governmental and non-sectoral international organization dealing with fiscal matters. It comprises taxpayers, their advisers, government officials, members of the judiciary and university professors and is therefore a unique forum for discussing international fiscal questions.
  • Retail Industry Leaders Association (RILA)
    Speaking Engagements / November 21, 2012
    Darrel Pearson and Claire Kennedy presents "Canada: Legal Tips & Traps for Retailers" at the Retail Industry Leaders Association (RILA) conference held in Dallas, Texas. 
  • Claire Kennedy Comments on GlaxoSmithKline Transfer Pricing Dispute
    In The News / October 18, 2012
    In the Globe and Mail article by Jeff Gray, "Supreme Court Backs Glaxo in Transfer-Pricing Dispute", Claire Kennedy comments on the Supreme Court of Canada decision that dismissed the federal government's claim the pharmaceutical company owed millions in unpaid taxes and upheld GlaxoSmithKline's current transfer pricing practices. "This does not give taxpayers carte blanche, at all," says Claire Kennedy. "...It's not as though it's creating a huge opening in terms of transfer pricing."
  • Canada Seeing Influx of Retailers: Primer On Compliance
    Articles / October 16, 2012
    Many household names in U.S. retailing have recently committed to Canada as a destination in which to expand their global market shares. Target, J. Crew, Justice (Tween), Nordstrom, Zumiez, Express, Tanger Outlet Centers, Kohl's and Marshalls have all established themselves in Canada or announced their intention to do so. Many others are actively exploring Canadian expansion opportunities. Published in the October/November 2012 issue of Executive Counsel.
  • Transfer Pricing & International Tax Conference
    Speaking Engagements / October 16, 2012
    At the Transfer Pricing & International Tax Conference at the Living Arts Centre of Mississauga, Claire Kennedy presents "The International Traders' Trifecta: International Tax, Transfer Pricing and Integrated Supply Chains" and Martin Sorensen presents "Transfer Pricing Controversy Management: Navigating CRA's New Audit Protocol, Competent Authority Arbitrations & Tax Risk Reporting".
  • International Bar Association 2012 Annual Conference
    Speaking Engagements / October 02, 2012
    At the IBA Annual Conference in Dublin, Claire Kennedy joins Chief Justice Myron T. Steele of the Delaware Supreme Court on the panel "Managing Related Party and Conflict of Interest Transactions".
  • International Fiscal Association 2012 Congress
    Speaking Engagements / September 30, 2012
    Claire Kennedy is a National Reporter for Canada on Services Establishments.
  • IBA Taxes Committee Working Group on Intangibles Transfer Pricing Guidelines
    Speaking Engagements / September 14, 2012
    Claire Kennedy co-chairs IBA Taxes Committee Working Group responding to the CD discussion draft on revisions to Chapter VI of the CD Transfer Pricing Guidelines re: Intangibles.
  • Claire Kennedy Appointed to University of Toronto's Governing Council
    Announcements / August 01, 2012
    The Lieutenant Governor in Council of Ontario appointed Claire Kennedy to the Governing Council of the University of Toronto.
  • Claire Kennedy Comments in Globe and Mail
    In The News / May 30, 2012
    In The Globe and Mail article by Jeff Gray, "Billions of Dollars in Taxes Hang in Balance at Top Court", Claire Kennedy comments on the GlaxoSmithKline Inc. transfer pricing case before the Supreme Court of Canada.
  • IBA Taxes Committee Working Group on PE Commentary
    In The News / February 10, 2012
    Claire Kennedy co-chairs IBA Taxes Committee Working Group responding to CD consultation on proposed changes to the Commentary on Article 5 (Permanent Establishment) of the CD Model Tax Convention.
  • International Bar Association 2011 Annual Conference
    Speaking Engagements / November 03, 2011
    At the IBA 2011 Annual Conference in Dubai, Claire Kennedy is a panellist during the session, "Getting the Most for your Dollar in an International Acquisition."
  • Canadian Transfer Pricing: Optimizing Canadian Expansion with a Unified Approach to Tax and Customs Transfer Pricing
    Articles / November 01, 2011
    Claire M.C. Kennedy, Darrel H. Pearson, "Canadian Transfer Pricing: Optimizing Canadian Expansion with a Unified Approach to Tax and Customs Transfer Pricing" (2011) 6 Global Trade and Customs Journal pp. 501-503.
  • FATCA Essentials
    Articles / November 01, 2011
    FATCA, or the Foreign Account Tax Compliance Act, is new U.S. tax legislation targeted at curtailing U.S. tax evasion and raising revenues. It imposes onerous and costly compliance burdens on Canadian financial institutions, including investment funds. Co-written with Alan W. Granwell; published in the CVCA Private Capital magazine, Volume 4, Winter 2011.
  • Transfer Pricing: Key to Higher Profit in Canada
    Articles / June 01, 2011
    Optimizing the opportunities for Indian companies in Canada should include planning to minimize income tax, customs duties, and value-added taxes. Originally published in the June 2011 edition of India Business Law Journal.  
  • American Bar Association, International Section – 2011 Spring Meeting
    Speaking Engagements / April 05, 2011
    At the 2011 Spring Meeting of the International section of the American Bar Association in Washington, DC, Darrel Pearson and Claire Kennedy present, "Transfer Pricing in a Global Supply Chain - Current Issues".
  • 4th Annual Women in Law: Success Factors
    Speaking Engagements / April 01, 2011
    At the 4th Annual Women in Law Conference: Success Factors, Claire Kennedy presents, "Women Lawyers and Marketing." Claire is also Chair of the first session.
  • International Bar Association Regional Conference
    Speaking Engagements / February 23, 2011
    Claire Kennedy is the Canadian panellist speaking on tax issues in infrastructure investments in the session "Olympic-size Investments: Business Opportunities and Legal Framework" in Rio de Janeiro.
  • Information Reporting a Priority of the Canadian and U.S. Tax Administrations
    Articles / February 22, 2011
     The Canada Revenue Agency (CRA) this year released Investigations Policy 2010-06 "Acquiring Information from Taxpayers, Registrants and Third Parties". The policy asserts the CRA's more muscular approach to obtaining documents and information in the course of taxpayer audits, particularly and controversially in the tax community, tax accrual working papers. Written by Claire Kennedy and Donald L. Korb and published in Corporate Finance (Vol. XVI, No. 4, p. 1886) by Federated Press.
  • Claire Kennedy Comments in Lexpert on Ruling in GlaxoSmithKline Inc. v. The Queen
    In The News / January 16, 2011
    In the January 2011 edition of Lexpert, where the publication rates its Top 10 Business Cases of 2010, Claire Kennedy comments on GlaxoSmithKline Inc. v. The Queen. Claire suggests that the court's decision is a victory for taxpayers: "What is important is the Federal Court's acknowledgement that transfer-pricing decisions don't exist in a vacuum and don't operate outside business realities... Here, the circumstances did not arise out of the non-arm's-length relationship between Glaxo and Glaxo group, but from the business realities imposed by the market power of the product." 
  • International Bar Association 2010 Annual Conference
    Speaking Engagements / October 05, 2010
    At the International Bar Association's 2010 Annual Conference in Vancouver, Claire Kennedy co-chairs the panel "Current Transfer Pricing in a Global Supply Chain".
  • Claire Kennedy Discusses Transfer Pricing in InsideCounsel
    In The News / October 01, 2010
    In "Canada's Federal Court of Appeal Offers Some Guidance on Transfer Pricing Issues," written by Julius Melnitzer for InsideCounsel, Claire Kennedy discusses the Federal Court of Appeal's decision in GlaxoSmithKline v. The Queen. According to Claire, the decision "established a sensible principle" for determining appropriate transfer pricing.
  • Claire Kennedy Discusses Transfer Pricing in Law Times
    In The News / September 27, 2010
    In Julius Melnitzer's Law Times article, "Glaxo Case Sets Principle for Dealing with Transfer Pricing", Claire Kennedy discusses the Federal Court of Appeal's July 26 transfer-pricing ruling in GlaxoSmithKline Inc. v. Canada, stating, "What is important is the Federal Court's acknowledgment that transfer-pricing decisions don't exist in a vacuum and don't operate outside business realities."
  • Claire Kennedy Quoted in Globe and Mail
    In The News / August 11, 2010
    Claire Kennedy comments on the use of transfer pricing by multinationals to minimize their tax bills following a recent ruling on an tax dispute between Ottawa and GlaxoSmithKline Inc. in, "Ruling Offers Reprieve for Corporate Tax Strategy," written by Jeff Gray for the Globe and Mail.
  • Narrowing of the Taxable Canadian Property Definition Welcomed by Foreign Vendors
    Articles / July 01, 2010
    On March 4, 2010, the government of Canada announced significant changes to the definition of "taxable Canadian property" in its 2010 Federal Budget. Published in Volume 16, No. 3 of Corporate Finance.
  • Claire Kennedy and Darrel Pearson Comment on Transfer Pricing in Lexpert
    In The News / June 01, 2010
    In "A Taxing Practice," Bennett Jones partners Claire Kennedy and Darrel Pearson comment extensively on the practice of transfer pricing, an area which has become a major focus for multinational enterprises seeking to move as much profit as possible to lower-tax jurisdictions. The article was written by Julius Melnitzer for the June issue of Lexpert magazine.
  • Trends in Transfer Pricing Drive the Need for a Unified Approach
    Updates / June 01, 2010
    Recent trends in transfer pricing are placing a renewed emphasis on transfer pricing compliance by businesses of all sizes and underscore the utility of a unified approach to tax and customs transfer pricing that optimizes benefits derived from dual planning and minimizes costly and protracted disputes. In this update, we highlight these key trends and discuss features and benefits of the unified approach.
  • Interface Between Customs Valuation and Transfer Pricing
    Articles / May 19, 2010
    Prepared for IE Canada's Transfer Pricing Forum 2010 (May 19-20, 2010), Claire Kennedy and Darrel Pearson's presentation, "Interface Between Customs Valuation and Transfer Pricing" highlights a unified approach to transfer pricing and customs valuation.
  • Transfer Pricing Forum 2010
    Speaking Engagements / May 19, 2010
    Darrel Pearson and Claire Kennedy present "Interface Between Customs Valuation and Transfer Pricing" at IE Canada's Transfer Pricing Forum 2010 (May 19-20, 2010) at the Toronto Airport Marriott Hotel.
  • Claire Kennedy Discusses Consolidated Business Tax Reporting
    In The News / April 15, 2010
    In Julius Melnitzer's Financial Post article, "Consolidation for Business Tax Reporting?", he examines a section of the 2010 federal budget that mentions the possibility the government will look at consolidated reporting. Claire Kennedy is quoted discussing the potential effects of the change on non-residents who remain subject to tax, stating, "It's a clear signal that Canada intends to be more user-friendly to foreign investors."
  • A Unified Approach to Tax & Customs
    Speaking Engagements / April 07, 2010
    Bennett Jones, Navigant Consulting, Inc. and the Pike Law Firm present, "A Unified Approach to Tax & Customs," an audio seminar on trends in tax and customs transfer pricing.
  • Canada Moves to Eliminate Tax and Simplify Tax Treatment of Exits
    Updates / March 05, 2010
    There was a change announced in the March 4, 2010, Canadian federal budget that will be quite beneficial for many private equity investors participating in the Canadian private company market.
  • Claire Kennedy Appointed to Neo Material Technologies Board of Directors
    Announcements / February 01, 2010
    In a press release, Neo Materials Technologies CFO Michael Doolan announced the appointment of Claire Kennedy to the company's Board of Directors.
  • Determining the Residence of a Trust - Tax Court of Canada Ruling in Garron et al. v. The Queen
    Articles / December 01, 2009
    In Garron et al. v. The Queen, Woods J. adopted a central management and control test in determining the residence of an offshore trust, which is a novel approach in Canadian law and represents a significant departure from the traditional test of residence of the trustee. The case is under appeal and pending the outcome, it will have ramifications for planning predicated on the residence of a trust in a particular jurisdiction.
  • CRA Releases Treaty Guidelines for US-owned ULCs but Planning is Required
    Updates / November 26, 2009
    The Canada Revenue Agency has released guidelines for distributions from ULCs to United States persons, notably dividends and in some cases interest, which would otherwise be subject to 25% withholding tax starting January 1, 2010. This jump in withholding rates from current levels is a consequence of anti-hybrid provisions introduced in the last round of amendments to the Canada-U.S. tax treaty.
  • International Bar Association 2009 Annual Conference
    Speaking Engagements / October 09, 2009
    At the IBA 2009 Annual Conference in Madrid, Claire Kennedy is a panelist during the session, "A Manual for Migrating Corporate Intangibles (and Can Governments Cope?)."
  • Transfer Pricing and Customs Valuation: Refund Opportunities and Tax Considerations
    Speaking Engagements / August 18, 2009
    Bennett Jones LLP partners, Darrel Pearson and Claire Kennedy hosted a seminar for the Association of International Automobile Manufacturers in Canada to discuss various transfer pricing and customs valuation opportunities and tax considerations for foreign multi-nationals importing goods from affiliates into Canada.
  • Cross-border Tax Disputes Cost Billions
    Updates / March 20, 2009
    Recent media reports that Chrysler's $1-billion transfer pricing dispute with Canadian tax authorities is jeopardizing the company's restructuring negotiations highlight the enormous cost of tax disputes to business and illustrate the critical importance of effective management of tax disputes.