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Tax

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  • Key Contacts
  • Recent Experience
  • Recent Recognition
  • Insights, News & Events
  • Download PDF
  • Recent Experience
  • Recent Recognition
  • Insights, News & Events

One of the main goals in a corporate transaction is to maximize profit while minimizing risk. This takes sound tax advice, given the complexities of the Canadian tax system and the range of rules and laws that govern domestic and foreign companies. Bennett Jones' corporate tax practice provides sophisticated tax planning advice and creative, incisive approaches to stewarding tax-efficient transactions and solving tax controversies (read more about our Tax Litigation & Dispute Resolution practice).

Tax is an essential element in helping clients maximize the return on their investments and operations. With that in mind, our tax lawyers are brought into transactions at the outset, and play a strategic role in the structuring and negotiation of mergers, acquisitions, divestitures, and all range of business ventures.

Our tax lawyers have a broad range of significant experience on both the Canadian and cross-border aspects of transactions in the resource, manufacturing, financial services, communications, technology, real estate, transportation, power (conventional and alternative) sectors. We advise private equity investors, pension funds and sovereign wealth funds and have been involved in the conversion of income trusts and royalty funds to corporate form.

Our practice includes all aspects of sales tax, GST, anti-dumping and other trade and commodity taxes. This commodity tax expertise is brought to bear both in connection with transactions involving cross-border flows of manufactured goods, financial services and commodities, and in tax controversy work.

As part of our practice we deal with the Canada Revenue Agency and international tax authorities in obtaining advance income tax rulings. We are called upon frequently to advise and provide opinions on proposed changes to both federal and provincial tax legislation and to advise on the handling of tax audits, and litigate tax reassessments. We also advise corporations in connection with stock option and other equity compensation arrangements.

Members of our group are active participants and leaders in tax organizations such as the Joint Committee on Taxation of the Canadian Bar Association and the Canadian Institute of Chartered Accountants, the International Fiscal Association, the Canadian Tax Foundation and the Canadian Petroleum Tax Society. Many of our lawyers are recognized as leading practitioners in the area of corporate taxation by Lexpert, Euromoney's guides to the world's leading lawyers and Chambers Global:The World's Leading Lawyers for Business.

Key Contacts

  • Thomas A. Bauer Thomas A. Bauer, Partner
  • Darcy D. Moch Q.C. Darcy D. Moch Q.C., Partner
  • Related Lawyers

Recent Experience

Excellon Resources Inc., in its $32.3-million acquisition of Otis Gold Corp by way of a Statutory Plan of Arrangement under the BCBCA.
Canadian Pacific Railway, in its public offering of $300-million aggregate principal amount of 3.05% notes due 2050.
Canadian Pacific Railway, in its public offering of US$500-million aggregate principal amount of 2.050% notes due 2030.
Canadian Utilities Limited, an ATCO company, in the sale of its entire Canadian fossil fuel-based electricity generation portfolio for approximately $835 million, which was completed in three stages, through the sale of its interest in the Cory project in Saskatchewan to SaskPower International Inc., a sale of its interest in the Brighton Beach project in Ontario to Ontario Power Generation Inc., and a sale of the balance of the applicable generation assets through a sale of its equity interest in ATCO Power Canada Ltd. to Heartland Generation Ltd., an affiliate of Energy Capital Partners.
United Active Living Inc., in matters related to ownership and operations of assisting living housing projects.
Kissner Group Holdings LP, completed its acquisition of NSC Minerals Ltd., a market-leading provider of salt products in Western Canada and the North Central United States, from an investor group led by Altas Partners.
Katanga Mining Limited, in its $7.6-billion rights offering financing backstopped by Glencore to fund debt repayment to Glencore.
Inuvialuit Development Corporation, as owner of Canadian North airline, in the merger of Canadian North and First Air (owned by Makivik Corporation), to create a Inuit-owned unified northern Canadian airline.
Northern Metalic Sales (F.S.J.) Ltd., an independent industrial supply company offering both traditional and non-traditional MRO products and related services, in its sale to affiliates of Side Management Ltd.
Cresco Labs Inc., in its acquisition of Tryke Companies, including the Reef Dispensary Portfolio, for US$252.5 million for Tryke operating assets plus US$30 million for Tryke real estate assets.
The special committee of Holloway Lodging Corporation, in the acquisition by Clarke Inc. of all of the issued and outstanding common shares of Holloway that it does not currently own by way of statutory plan of arrangement.
Devon Canada Corporation and Devon Canada Crude Marketing Corporation, in their approx. $3.8-billion sale of substantially all of their assets to Canadian Natural Resources Limited.
Zedi Inc., in the sale of its software and automation businesses to affiliates of Emerson Electric Co.
The initial consenting senior unsecured noteholders in Bellatrix's recapitalization pursuant to the CBCA.
Broadridge Financial Solutions, Inc., in its approximately US$300-million acquisition of RPM Technologies.
CIP Capital Management LLP, as Canadian counsel, in its acquisition of People 2.0, Inc.
BSM Technologies Inc., in its approximately $117.3-million sale to Geotab Inc. by way of plan of arrangement.
ATCO Ltd., completes private placement of $200M fixed-to-floating subordinated notes.
Algonquin Power Utilities, registered fixed to floating subordinated notes southbound MJDS offering.
The Ad Hoc Committee of Unsecured Debtholders in the US$4 billion recapitalization of Concordia International Corp.
Canadian counsel to Baker Technologies, Inc., a Colorado-based provider of cannabis-specific customer relationship management software, in its business combination with Santé Veritas Holdings Inc., Briteside Holdings, LLC and Sea Hunter Therapeutics, LLC.
Baker Technologies, Inc., a Colorado-based provider of cannabis-specific customer relationship management software, in its proposed business combination with Santé Veritas Holdings Inc., Briteside Holdings, LLC and Sea Hunter Therapeutics, LLC.

Recent Recognition

Chambers Canada
Ranked, Tax
Chambers Global: The World's Leading Lawyers for Business
Ranked, Tax
The Legal 500: Canada
Ranked, Tax
The Canadian Legal Lexpert Directory
Most Frequently Recommended, Corporate Tax, Calgary
Consistently Recommended, Corporate Tax, Toronto
World Tax
Ranked, Tax
Ranked, Tax Controversy
Ranked, Transactional Tax

Insights, News & Events

Announcements

Bennett Jones in Chambers Global 2021

February 22, 2021
       

Articles

Transfer Pricing in the Time of COVID-19

February 19, 2021
       

Blog

Supreme Court of Canada Declines to Hear the Cameco Landmark Transfer Pricing Case

February 18, 2021
       

Blog

Transfer Pricing in the Time of COVID-19

February 09, 2021
       

In the News

Sophie Virji in Global Lawyers of Canada's Womxn in Law Series

January 28, 2021
       

Articles

Bennett Jones on Tax Disputes - January 2021

January 14, 2021
       

Articles

Martin Sorensen and Hennadiy Kutsenko in The Lawyer's Daily

January 14, 2021
       

Blog

Flow-Through Shares: Draft Legislation Released to Extend Expenditure Periods

December 18, 2020
       

Announcements

Twenty-Five Bennett Jones Lawyers in Lexpert/ALM 500 Directory

December 17, 2020
       

Blog

Not Just a Rent Subsidy: How CERS May Dramatically Affect You

November 20, 2020
       

Articles

Bennett Jones on Tax Disputes - November 2020

November 02, 2020
       

Announcements

Bennett Jones Acts for Cenovus in $23.6-billion Combination with Husky

October 27, 2020
       

Articles

Marshall Haughey and Wade Ritchie in Canadian Tax Focus

October 26, 2020
       

Announcements

Bennett Jones Advises on $3.2-Billion Agreement to Acquire K+S Americas Salt Business, Including Morton Salt and Windsor Salt

October 05, 2020
       

Announcements

Bennett Jones' Transfer Pricing Leaders 2021

October 02, 2020
       

Announcements

Bennett Jones Women in Tax Leaders 2021

October 02, 2020
       

Announcements

Bennett Jones' World Tax Leaders 2021

October 02, 2020
       

Blog

Formula-Based Employee Appreciation Rights: New CRA Positions Raise the Spectre of Salary Deferral Arrangement Treatment

September 29, 2020
       

Blog

Rules of Reassessment: First Order Issued Under the Time Limits and Other Periods Act (COVID-19)

September 28, 2020
       

Announcements

Bennett Jones is Recognized in Chambers Canada 2021

September 10, 2020
       

Speaking Engagements

Scott Bodie and Marshall Haughey on Debt Forgiveness and Property Foreclosure

September 09, 2020
       

Articles

Bennett Jones on Tax Disputes - September 2020

September 03, 2020
       

Articles

Canadian Accountant on Me Too Defeats You Too in Tax Court

August 26, 2020
       

Blog

Me Too Defeats You Too in Tax Court

August 24, 2020
       

Blog

New Trust Reporting Rules

August 18, 2020
       

Blog

Limitation Periods for Tax Disputes Might Now Be Extended

August 04, 2020
       

Articles

Bennett Jones on Tax Disputes - August 2020

July 31, 2020
       

Blog

Canada Emergency Wage Subsidy: New Asset Acquisition Rules

July 28, 2020
       

Blog

Space Travel and Taxes: A Cautionary Tale of Shareholder Benefits

July 27, 2020
       

Blog

Canada Emergency Wage Subsidy: Proposed Extension until December 19, 2020 and Redesign

July 20, 2020
       

Blog

The Multilateral Instrument and Canadian Tax Planning Considerations: The Clock is Ticking

July 20, 2020
       

Blog

Alberta’s Recovery Plan

July 07, 2020
       

Blog

Alberta Advantage: Reduced Corporate Tax Rate Effective July 1, 2020

June 30, 2020
       

Blog

Just Say "No": Acceptance of a Secret Trust in Bergler v Odenthal

June 30, 2020
       

Articles

Bennett Jones on Tax Disputes - June 2020

June 24, 2020
       

Speaking Engagements

Ed Kroft on Tax Dispute Resolution During the Pandemic

June 23, 2020
       

Blog

Working From Home During a Pandemic—The Expense Conundrum

June 19, 2020
       

Articles

Tax Planning Strategies in a Market Downturn: Loss

June 19, 2020
       

Articles

Tax Planning Strategies in a Market Downturn: Trusts

June 12, 2020
       

Blog

Best Practice Considerations for Virtual Execution of Estate Planning Documents

June 10, 2020
       

Blog

Tax Court of Canada Update

June 08, 2020
       

Articles

Tax Planning Strategies in the Market Downturn: Estate Freezes, Income Splitting

June 04, 2020
       

Articles

Bennett Jones on Tax Disputes - May 2020

May 26, 2020
       

Blog

Managing the Tax Residency of Foreign Affiliates in the Face of the COVID-19 Restrictions

May 25, 2020
       

Blog

The Reopening of the Tax Court of Canada: Timeline and Protocols as at May 15, 2020

May 19, 2020
       

Speaking Engagements

Fundamentals of Oil & Gas Taxation

May 19, 2020
       

Announcements

Fifteen Bennett Jones Lawyers in Lexpert's Special Edition on Technology

May 13, 2020
       

Blog

Applying for the Canada Emergency Wage Subsidy: What Are My Risks?

April 28, 2020
       

Blog

Applications for the Canada Emergency Wage Subsidy Open on April 27, 2020

April 24, 2020
       

Articles

Mischief managed? The new voluntary disclosures program

April 20, 2020
       

Blog

Are You Liable For Another Person’s Unpaid Federal or Provincial Taxes?

April 17, 2020
       

Blog

COVID-19 Relief for Employers: The Canada Emergency Wage Subsidy is Approved

April 13, 2020
       

Blog

Extended Federal Tax Filing, Payment and Remittance Deadlines Amid COVID-19

April 01, 2020
       

Blog

British Columbia Announces COVID-19 Action Plan

March 24, 2020
       

Blog

Modified Deadlines for Federal Tax Litigation Proceedings

March 23, 2020
       

Blog

COVID-19 Tax Updates from the Alberta Government and the CRA

March 20, 2020
       

Blog

Canada's COVID-19 Economic Response Plan

March 19, 2020
       

Blog

Voluntary Disclosure to CRA—It Ain’t What It Used To Be

March 12, 2020
       

Articles

Federal Court of Appeal: Inducement Taxable as Restrictive Covenant Payment

March 04, 2020
       

Blog

Federal Court of Appeal Upholds Treaty-Based Canadian Holding Structure

February 26, 2020
       

Announcements

Bennett Jones in Chambers Global 2020

February 13, 2020
       

Blog

FCA Confirms that an Inducement is Taxable as a Restrictive Covenant Payment

February 04, 2020
       

Articles

B.C. Court of Appeal Gives New Life to Post-Fairmont Rectification

January 2020
       

Articles

The Dawn of a New Day: The Preliminary Ruling Docket (Tax Court of Canada)

January 2020
       

Announcements

James Morand Joins Bennett Jones as Partner in Toronto

December 16, 2019
       

Announcements

Twenty-three Bennett Jones Lawyers in Leading 500 in Canada

December 13, 2019
       

Speaking Engagements

Martin Sorensen on Transparency & Disclosure

December 1-3, 2019
       

Announcements

Bennett Jones is Top-Tier in The Legal 500

November 18, 2019
       

Blog

Rectification Strikes Back: B.C. Court of Appeal Allows Rectification of Tax Mistake

November 13, 2019
       

Articles

Bennett Jones on Tax Disputes November 2019

November 2019
       

Speaking Engagements

Revisiting Taxpayer Relief and Ministerial Discretion

October 28-29, 2019
       

Announcements

Bennett Jones' Women in Tax Leaders 2020

October 01, 2019
       

Announcements

Bennett Jones' World Tax Leaders 2020

October 01, 2019
       

Announcements

Bennett Jones' World Transfer Pricing Leaders 2020

October 01, 2019
       

Speaking Engagements

Martin Sorensen on Tax and Intellectual Property Transactions

September 13, 2019
       

Blog

Tax Treaty Benefits Threatened as Canada Completes Ratification of OECD's Multilateral Instrument

September 05, 2019
       

In the News

Martin Sorensen in Canadian Lawyer on how Whistleblowing Pays Off

September 03, 2019
       

Blog

Whistleblowing Pays Off—New CRA Data on First Payments to Informants

August 21, 2019
       

Articles

Bennett Jones on Tax Disputes - August 2019

August 14, 2019
       

Articles

Bennett Jones on Tax Disputes - June 2019

June 17, 2019
       

Speaking Engagements

Resource Industry Panel

June 06, 2019
       

Blog

Bennett Jones Speaks before Senate Committee on Tax Issues for Energy Investments

May 30, 2019
       

Speaking Engagements

Anatomy of a Tax Dispute Understanding the CRA Audit and Objection Process

May 27, 2019
       

Articles

Bennett Jones on Tax Disputes

April 10, 2019
       

Updates

New Ratifications of the OECD's Multilateral Instrument Put Canadian Resource Holding Structures at Risk

April 03, 2019
       

Updates

Business Measures in 2019 Federal Budget

March 22, 2019
       

Updates

Not Just Linear Property Tax Priorities: Alberta Court of Appeal on Abuse of Process and Mootness

February 19, 2019
       

Blog

CBCA Private Corporations Subject to New Shareholder Record-Keeping Requirements

February 11, 2019
       

Articles

Creditors Cheer SCC Decision on GST Debts

February 2019
       

Blog

New GST/HST Rules Enacted for Fund Management Fee Arrangements

January 09, 2019
       

Updates

Orders for Consolidation and Common Hearings Under Tax Court Rule 26

January 04, 2019
       

Updates

The 2018 Federal Fall Economic Statement—Canada's Response to U.S. Tax Reform

December 04, 2018
       

Speaking Engagements

Blockchain, Cyrptocurrency, and More: An Uneasy Fit with the Tax and Legislative Framework

November 25-27, 2018
       

Speaking Engagements

GAAR: 30 Years Later

November 25-27, 2018
       

Articles

Large Corporation Objection and Appeal Process: What’s Wrong with This Picture"

2018
       

Blog

No Deemed Trust for Unremitted GST and HST Post-Bankruptcy

November 13, 2018
       

Updates

Property Tax Priorities in Alberta Insolvency Proceedings: Current Uncertainty

November 12, 2018
       

Speaking Engagements

Canadian Petroleum Tax Society, Fall Breakfast Series 2018

October 17, 2018
       

Blog

Bank Loan Repayments May Be Seized Due to Super Priority of Crown for GST/HST

October 16, 2018
       

Updates

Introducing the U.S.-Mexico-Canada Agreement (USMCA)

October 04, 2018
       

Articles

Global Legal Insights on Blockchain and Cryptocurrency Legislation

September 24, 2018
       

Articles

Concordia International Corp. Completes US$4 Billion Recapitalization

September 06, 2018
       

In the News

Martin Sorensen in National Post on Tax Audits Gone Bad

September 06, 2018
       

Articles

Crossing Provincial Lines: Alberta Courts Tackle 20(1)(C)

June 14, 2018
       

Speaking Engagements

Canadian Tax Foundation 2018 Prairie Provinces Conference

May 28-29, 2018
       

Speaking Engagements

Anti-Avoidance Measures of General Nature and Scope, GAAR, and Other Rules

May 16, 2018
       

Speaking Engagements

Cross-Border Cash Pooling Arrangements: Some Practical Problems

May 15-16, 2018
       

Speaking Engagements

IFA Canada - Recent Canadian Developments

May 15, 2018
       

Speaking Engagements

2018 Tax Executives Institute

April 12, 2018
       

Updates

Status of Measures Targeting Private Corporations Following the 2018 Federal Budget

March 12, 2018
       

In the News

Claire Kennedy in Lexpert on Tax Reform and Cross-Border Commerce

February 21, 2018
       

Blog

Bartering with Bitcoin: Canadian Tax Implications of Using Cryptocurrency in Business Transactions

February 15, 2018
       

Blog

Getting In on Bitcoin: Canadian Income Tax Implications of Cryptocurrencies

February 12, 2018
       

Blog

Implication of Daishowa to Purchasers

January 19, 2018
       

In the News

Bennett Jones Acts for ECi Software Solutions in Cross-Border Acquisition

January 04, 2018
       

Articles

Canadian Tax Focus

2018
       

Blog

VDP Overhaul Coming Sooner Than You Thought

December 20, 2017
       

Announcements

Anu Nijhawan Elected to Canadian Tax Foundation’s Board of Governors

December 06, 2017
       

Blog

Disclosure Delayed May Be Disclosure Denied

December 01, 2017
       

In the News

Canadian Lawyer on Claire Kennedy: Canada's Most Powerful Women

November 29, 2017
       

Announcements

Schlumberger/Torxen Purchase Cenovus Assets

October 18, 2017
       

Announcements

Claire Kennedy and Anu Nijhawan ITRs Women in Tax Leaders

September 25, 2017
       

Blog

Growing Concerns with Proposed Amendments Affecting Private Businesses and their Shareholders

August 10, 2017
       

Blog

No Appeal of BP Canada Decision on Working Papers, Announces CRA

June 05, 2017
       

In the News

Claire Kennedy on Cover of Lexpert on Tax Competition

May 05, 2017
       

In the News

Claire Kennedy and Philip Ward in ABA Tax Times

May 03, 2017
       

Blog

No Routine Access by CRA to Tax Working Papers Rules the Federal Court of Appeal

April 05, 2017
       

Updates

Budget 2017: Changes to Canadian Exploration Expense and Flow-Through Shares

March 24, 2017
       

Announcements

Four Bennett Jones Practices Ranked Band 1 by Chambers Global 2017

March 16, 2017
       

Speaking Engagements

International Compliance Professional Association EU Conference 2017

March 12-15, 2017
       

Blog

Report a Canadian Tax Evader and Make Money?

February 24, 2017
       

Articles

Rio Tinto Alcan v. The Queen: Welcome Expansion of the Canadian Tax Deductibility of M&A Transaction Expenses

February 2017
       

In the News

Matthew Peters in Lexpert on Top 10 Business Decisions of 2016

February 13, 2017
       

Blog

CRA Releases New Guidelines Regarding Canadian Exploration Expenses

February 09, 2017
       

Blog

Amendments to Alberta's Municipal Government Act Likely to Reduce Time and Cost of Property Tax Review Process

January 23, 2017
       

Articles

2016 Tax Conference Report

2017
       

Speaking Engagements

Canadian Tax Foundation Annual Conference 2017

2017
       

In the News

Claire Kennedy in Bloomberg on Transfer Pricing and Voluntary Disclosure

December 13, 2016
       

Blog

SCC Confirms General Intention not Sufficient for Rectification in Tax Cases

December 09, 2016
       

Articles

Report of the Proceedings of the Sixty-Eight Tax Conference

November 27, 2016
       

Speaking Engagements

Canadian Tax Foundation Annual Conference (2016)

November 27-29, 2016
       

Blog

What Trump's Tax Plan Means For Canada

November 15, 2016
       

Updates

The Latest Word on Subsequent Legislative History and the GAAR

November 01, 2016
       

Speaking Engagements

Canadian Petroleum Tax Society September Luncheon

September 22, 2016
       

In the News

21 Bennett Jones Infrastructure Lawyers Canadian Leaders

August 26, 2016
       

Publications Section

Applicability of GST on Medical Marijuana Obtained under the MMPR

July 26, 2016
       

In the News

Claire Kennedy in Bloomberg: CIT Interest Income Case in Canada Tax Court

July 22, 2016
       

In the News

Claire Kennedy in Bloomberg on Rio Tinto Canada Tax Case

July 22, 2016
       

Articles

Canada Revenue Agency Views on Taxable Canadian Property Determinations Involving Subsidiaries

July 2016
       

In the News

Martin Sorensen in Lexpert: Does CRA Owe Taxpayers a Duty of Care?

June 16, 2016
       

In the News

Claire Kennedy and Robert McCue on the BEPS Effect

June 15, 2016
       

In the News

Martin Sorensen in Lexpert on Duty of Care

April 14, 2016
       

In the News

Claire Kennedy in Bloomberg on Transfer Pricing and Tax Breaks

March 22, 2016
       

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