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Anu Nijhawan KC

M&A, Corporate Financing and International Tax Lawyer

Lead Director and Head of Tax Department

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

Curtis A. Cusinato

Cross-border Mergers and Acquisitions and Capital Markets Lawyer

Co-Head of Mergers & Acquisitions Services

Tyler B. McAuley

Corporate Lawyer at Bennett Jones Toronto

Kevin Myson

Energy & Corporate Lawyer | M&A, Natural Resources & Transport

Canada&rsquo;s M&amp;A market remained resilient through the first half of 2026, with deal activity increasingly concentrated in large, strategically important transactions despite ongoing economic and geopolitical uncertainty. This quarterly update explores the sectors driving Canadian M&amp;A, including energy, digital infrastructure and real estate, and examines how policy developments, AI-related demand and shifting investment priorities are shaping dealmaking trends. It also highlights key opportunities and considerations for investors as activity is expected to accelerate in the second half of the year.

Canadas Q2 2026 MA Landscape

Sustained Momentum Driven by Energy Investment and AI-Related Demand

Canada's Q2 2026 M&A Landscape

Jessica Kennedy

Regulatory Lawyer at Bennett Jones Calgary

Martin Ignasiak KC

Energy & Industrial Projects Lawyer

Head of Energy Regulatory Services

Larissa D. Lees

Associate

On June 9, 2026, the Government of Alberta enacted the Data Centre Regulation, AR 117/2026 under the Electric Utilities Act, codifying the province&rsquo;s &ldquo;bring your own generation&rdquo; policy and providing the legal foundation for the Alberta Electric System Operator&rsquo;s grid connection process for large data centres.&nbsp;

Albertas BYOG Framework

Alberta's BYOG Framework: What Data Centre and Generation Proponents Need to Know

J. Sébastien A. Gittens

Technology Lawyer & Trademark Agent

Partner, Trademark Agent

Caroline Poirier

IT, Privacy & Data Protection Lawyer

Stephen D. Burns

Energy & Infrastructure Technology Lawyer | IT/OT & Markets

Earlier this month, the federal government introduced the proposed federal Protecting Privacy and Consumer Data Act (PPCDA) &ndash; a signal that Canada&rsquo;s private-sector privacy landscape may undergo significant transformation imminently. To assist organizations that conduct business in Canada with their potential compliance efforts with respect thereto, the following is intended to provide a non-exhaustive, high-level comparison between: (i) the PPCDA; (ii) Canada's Personal Information Protection and Electronic Documents Act (PIPEDA); (iii) Qu&eacute;bec&rsquo;s Act respecting the protection of personal information in the private sector (the Qu&eacute;bec Privacy Act, as amended by Law 25); and (iv) the Personal Information Protection Acts of Alberta and British Columbia (collectively, the PIPAs).

A Comparison of the PPCDA PIPEDA Quebecs Privacy Act and PIPA

A Comparison of the PPCDA, PIPEDA, Quebec's Privacy Act and PIPA

Adam W. Taylor

Corporate Commercial Lawyer at Bennett Jones Toronto

Matthew Flynn

Technology Transaction Lawyer at Bennett Jones Toronto

Simon Grant

Financial Services & Regulatory Lawyer

Partner 

Canada's proposed Consumer-Driven Banking Regulations provide the first detailed framework for implementing the country's open banking regime, setting out requirements for accreditation, security, consent, data sharing and ongoing compliance. The proposed regulations also highlight the growing connection between consumer-driven banking and privacy reform, particularly as Canada advances broader data mobility rights. Organizations should assess the potential impact of the framework and consider participating in the current consultation process. 
<div>&nbsp;</div>

Canada Advances Consumer Driven Banking Framework with Proposed Regulations

Canada Advances Consumer-Driven Banking Framework with Proposed Regulations

Ruth E. Promislow

Privacy, Cybersecurity & AI Lawyer

On June 4th, 2026, the federal government released Canada&rsquo;s National Artificial Intelligence Strategy: AI for All (the Strategy). The Strategy aims to ensure that artificial intelligence serves Canadians, strengthens businesses and communities and enhances Canada&rsquo;s control over its technological future through six key pillars.

Canadas AI for All Strategy Building Trust Innovation and Sovereignty in the Era of AI

Canada’s AI for All Strategy: Building Trust, Innovation and Sovereignty in the Era of AI

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The 2010 Federal Budget: Impact on the Taxation of Employee Stock Options

From the Same Authors