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Jared A. Mackey

Corporate Tax Lawyer at Bennett Jones Calgary

Partner

Article 4(1) of Canada’s income tax treaties defines a “resident” of a Contracting State to mean a person who is subject to comprehensive tax in that State “by reason of” various criteria, such as domicile, residence, place of management or any other criterion of a similar nature.

Deemed US Corporation not a US Treaty Resident

Deemed U.S. Corporation not a U.S. Treaty Resident: HRMC v. GE Financial Investments Ltd.

Spencer Brown

Tax Lawyer at Bennett Jones Calgary

Associate

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

Anu Nijhawan

M&A, Corporate Financing and International Tax Lawyer at Bennett Jones Calgary

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

Wade Ritchie

With the enactment of Bill C-47 on June 22, 2023, Canada's enhanced mandatory disclosure rules are now fully in effect. These rules, which were first announced in the 2021 Canadian federal budget:
<ul>
 <li>expand the prior rules for "reportable transactions";</li>
 <li>include new reporting requirements for "notifiable transactions" and "uncertain tax treatments"; and</li>
 <li>impose new punitive consequences, including penalties and extended reassessment periods, for failing to comply with the disclosure requirements.</li>
</ul>

Enhanced Reportable Transaction Rules Take Effect

Stephen D. Burns

Technology Lawyer, Intellectual Property Lawyer at Bennett Jones Calgary

Partner, Trademark Agent

Benjamin K. Reingold

Intellectual Property Litigation Lawyer at Bennett Jones Calgary

David Wainer

Commercial Transactions Lawyer at Bennett Jones Calgary

This end-of-year overview examines the Federal Government&rsquo;s rapid expansion of AI-related funding in 2025, from large-scale investments in data centres and public compute infrastructure to programs supporting AI access, adoption and domestic research. It also explores the new commitments announced in Budget 2025 and signals key trends to watch in 2026 as Canada strengthens its AI ecosystem.

Canadas AI Efforts in 2025 A Year in Review

Canada's AI Efforts in 2025: A Year in Review

Laura Inglis

Commercial Litigation Lawyer at Bennett Jones Edmonton

Christine Plante

Civil Fraud Recovery, Employment and Shareholder Disputes Lawyer at Bennett Jones Calgary

David M. Price

Employment Services Lawyer at Bennett Jones Calgary

Effective January 1, 2026, Alberta will increase job-protected long-term illness and injury leave from 16 to 27 weeks. This update aligns Alberta with other leading Canadian jurisdictions that recently implemented similar extended leaves. Employers will need to revisit their workplace policies to ensure compliance with the new requirements. The blog explains the legislative amendments and their implications for employers.

Alberta Aligns with Other Provinces in Extending Long Term Illness and Injury Leave

Ashley L. Paterson

Commercial Litigation Lawyer at Bennett Jones Toronto

Morgan Sutherland

Lawyer at Bennett Jones Toronto

Associate 

Health Canada has proposed amendments to the Medical Devices Regulations focused on modernizing the MDEL framework. The changes would affect importer&ndash;distributor relationships, mandatory supplier disclosures, and safety documentation requirements. This update summarizes the key proposals and their potential impacts on MDEL holders and applicants.

Health Canada Proposes Amendments to MDEL Holders and Applicants

Cameron Penn

Litigation Lawyer at Bennett Jones Calgary

Tami Oguntona

Articling Student at Bennett Jones in Calgary 

Articling Student 

British Columbia has introduced new limits on when employers may request sick notes and created a 27-week unpaid leave for serious personal illness or injury. This update outlines the key legislative changes and their practical impact on employer policies.

What the Doctor Ordered British Columbia

What the Doctor Ordered: British Columbia Updates Rules on Employee Sick Notes and Introduces Serious Personal Illness and Injury Leave

This article explores how Ad Standards Canada&rsquo;s Code applies to influencer marketing and AI-generated content, focusing on accuracy, disclosure and testimonial rules, along with best practices for compliance.

Canadian Code of Advertising Standards for Influencer Marketing

Canadian Code of Advertising Standards for Influencer Marketing: Key Clauses and Application to AI-Generated Content and Influencers 

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

From the Same Authors