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Edwin G. Kroft KC

Tax Litigation Lawyer at Bennett Jones

Partner

Andrew Young

Tax Lawyer at Bennett Jones Toronto

Associate

Spencer Brown

Tax Lawyer at Bennett Jones Calgary

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

Bennett Jones on Tax Disputes February 2025

Bennett Jones on Tax Disputes: February 2025

Jared A. Mackey

Corporate Tax Lawyer at Bennett Jones Calgary

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

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

The <a href="https://www.budget.canada.ca/2023/home-accueil-en.html">2023 Canadian Federal Budget</a>, released March 28, 2023, provides particulars on the proposed new two percent tax on share buybacks and expands the proposal to apply to repurchases of equity by certain trusts and partnerships.

Canada Clarifies and Expands Proposal for Equity Buyback Tax

The federal government's <a rel="noopener noreferrer" rel="noopener noreferrer" href="https://www.budget.gc.ca/fes-eea/2022/home-accueil-en.html" target="_blank">2022 Fall Economic Statement</a>, released on November 3, 2022, introduced a new tax on share buybacks by public corporations in Canada. Under the proposal, which would come into force on January 1, 2024, a two percent corporate-level tax would apply on the "net value" of a corporation's share buybacks.

Canada Proposes New Tax On Share Buybacks

Benjamin K. Reingold

Intellectual Property Litigation Lawyer at Bennett Jones Calgary

Stephen D. Burns

Technology Lawyer, Intellectual Property Lawyer at Bennett Jones Calgary

Partner, Trademark Agent

Online sweepstakes in Canada offer strong marketing potential but face strict legal requirements around compliance, privacy and advertising. With AI now driving personalization, fraud detection and data analysis, businesses must balance innovation with transparency and fairness.

Navigating the World of Online Canadian Sweepstakes

Navigating the World of Online Canadian Sweepstakes: Legal Pitfalls and the Role of AI

Wesley R. Novotny

Wade Ritchie

Zachary Thacker

Canada has proposed amendments to its employee ownership trust (EOT) rules that improve clarity, reduce risks from disqualifying events, and expand access to the C$10 million capital gains deduction. These changes make EOTs a more practical and attractive succession planning tool for business owners.

New Legislative Proposals Boost the Appeal of Employee Ownership Trusts

Ruth E. Promislow

 Data Security and Privacy, Commercial Litigation Lawyer at Bennett Jones Toronto

Caroline Poirier

Information Technology, Privacy and Data Protection Lawyer at Bennett Jones Montreal

Suzie Suliman

Commercial Transactions Lawyer at Bennett Jones Toronto

Associate, Trademark Agent

Canadian privacy regulators found TikTok improperly collected children&rsquo;s data and lacked valid consent. TikTok will implement new privacy measures, emphasizing stronger protections for youth and transparency under Canadian law.

Joint Privacy Commissioner Investigation of TikTok Key Take Aways

Joint Privacy Commissioner Investigation of TikTok Key Take-Aways

Antoine Messervier

Tax Lawyer at Bennett Jones Vancouver

Issue 38 of Bennett Jones on Tax Disputes, published on Taxnet Pro by Thomson Reuters, features a review of notable tax cases, recent court guidance and ongoing appeal activity. This issue includes several articles from members of Bennett Jones&rsquo; Tax group.

Bennett Jones on Tax Disputes Issue 38 September 2025

Bennett Jones on Tax Disputes: September 2025

Lorelei Graham

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

It is clear that the global push for green innovation is no longer just aspirational, it is structural. Over the past decade, countries around the world have implemented a mosaic of policies to accelerate environmentally friendly technologies, many of which intersect with intellectual property. But intellectual property (IP) is just one piece of a much larger innovation puzzle.
Increasingly, we see that financial incentives, regulatory frameworks and IP protections are working in tandem to drive green agri-tech. Incentives can include tax credits, substantial grants supporting climate-smart agriculture, subsidies for carbon farming, or &ldquo;patent box&rdquo; regimes offering reduced tax rates on income from green IP, all of which then shape the behavior of startups and researchers alike. However increasingly the conversation is expanding beyond patents and grants into including carbon markets.

Fast Tracks and Green Gaps Part V

Fast Tracks and Green Gaps Part V: From Carrots to Carbon Credits: How the World is Powering Green Agri-Tech Beyond IP

Suzanne Byrne and Spencer Brown on Tax and Trust

From the Same Authors