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Anu Nijhawan KC

M&A, Corporate Financing and International Tax Lawyer

Lead Director and Partner

Hennadiy Kutsenko

Tax Lawyer at Bennett Jones Toronto

Counsel

Talia K. Bregman

Management-side Employment Lawyer

Employment Services, National Practice Group Leader

Recent guidance from the Organisation for Economic Co-operation and Development provides important clarity on when cross-border remote work arrangements may give rise to a permanent establishment under international tax treaties. The analysis focuses on key indicators such as the duration of remote work and whether there is a commercial reason for an employee&rsquo;s presence in a jurisdiction. The article also outlines practical steps employers can take to mitigate tax risk and manage a globally distributed workforce.

Remote Work Without Borders But Not Necessarily Without Tax Consequences

Remote Work Without Borders—But Not Necessarily Without Tax Consequences: OECD Guidance for a Post-Pandemic World

Jared A. Mackey

Corporate Tax Lawyer at Bennett Jones Calgary

Partner

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

Tax Considerations on the Repayment of Discounted Foreign Currency Obligations

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

Incentivizing Employees Avoiding a Salary Deferral Arrangement

Incentivizing Employees: Avoiding a Salary Deferral Arrangement

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

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

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

Brian P. Reid

Construction & Energy Litigation Lawyer

Kaamil Khalfan

Commercial Litigation Lawyer at Bennett Jones Calgary

Associate

Aaron Tell

Lawyer at Bennett Jones Calgary 

Associate 

The Alberta Court of King's Bench has clarified that the two-year trial deadline under the Prompt Payment and Construction Lien Act does not apply once a construction lien and certificate of lis pendens have been discharged from title through the posting of security. In 1951789 Alberta Ltd v Britannia Block General Partnership Inc., the Court confirmed that section 46(2) applies only where a lien and CLP remain registered against the land. The decision provides important guidance for parties involved in construction lien disputes and highlights the distinction between statutory lien remedies and delay-based applications under the Alberta Rules of Court.

Security Measures The Alberta Court of Kings Bench Clarifies

Security Measures: The Alberta Court of King's Bench Clarifies the Law of Lien Security

J. Sébastien A. Gittens

Technology Lawyer & Trademark Agent

Partner, Trademark Agent

Ruth E. Promislow

Privacy, Cybersecurity & AI Lawyer

Caroline Poirier

IT, Privacy & Data Protection Lawyer

On June 15, 2026, the federal government introduced Bill C-36 to modernize Canada&rsquo;s federal private sector privacy laws and continue the implementation of Canada's National Artificial Intelligence Strategy: AI for All.

Bill C 36 and Canadian Privacy Reform

Five Things Businesses Should Know Now

Bill C-36 and Canadian Privacy Reform

Matthew J. Hunt

Corporate Lawyer at Bennett Jones Toronto

Elizabeth K. Dylke

Corporate and Private Funds Lawyer

John Lawless

Corporate & Securities Lawyer | Private Equity

Globally, private equity markets have moderated in the first half of 2026 as new and ongoing geopolitical developments are shifting the calculus on dealmaking. However, selectivity, discipline and creativity continue to generate deals, with North America attracting the lion's share of private market activity. At the year's midpoint, there is good reason to believe that the back half of 2026 will see a rallying of activity, especially in select sectors like IT, infrastructure and energy.&nbsp; 
<div>&nbsp;</div>

The H1 2026 PE Briefing

Mid-Year Insights on Deal Activity and the Road Ahead

Christine Plante

Employment Lawyer | HR Legal Counsel

Sara G. Parchello

Employment Lawyer at Bennett Jones Toronto

Tami Oguntona

Articling Student at Bennett Jones in Calgary 

Articling Student 

Bill C-31 proposes significant amendments to the Canada Labour Code that would prohibit most post-employment non-compete clauses and potentially other employment-related restrictions in federally regulated workplaces. While the legislation has not yet been enacted, employers should begin assessing the potential impact of the proposed changes, including the limited exemptions available for certain business transactions and senior executive roles.

Restricting Covenants in Federal Workplaces

Proposed Updates to Canada Labour Code Expected To Prohibit Post-Employment Restrictive Covenants

Suzie Suliman

Commercial Transactions Lawyer at Bennett Jones Toronto

Associate, Trademark Agent

The 2025 GPEN Sweep highlights growing global scrutiny of how digital platforms handle children&rsquo;s personal information, revealing increased data collection alongside limited safeguards. While improvements have been made in areas such as account deletion, significant gaps remain in effective age assurance, transparency, and protective design. The findings signal that regulators are likely to intensify guidance and enforcement efforts to better protect children&rsquo;s privacy online.

Global Privacy Sweep Highlights Growing Expectations for Childrens Privacy Online

Global Privacy Sweep Highlights Growing Expectations for Children's Privacy Online

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Claire Kennedy and Anu Nijhawan ITRs Women in Tax Leaders

From the Same Authors