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Economic Outlook: Saving, Investment and Productivity Growth - 2024 Mid-Year

Discussions with investors in Asia, Europe and the United States provide valuable insight into the state of Canada’s economy. Views reflect reality and perception. Both matter. Investors universally envy our potential, our...more

Bennett Jones Fall 2022 Economic Outlook: Managing Risks and Taking Action

Renowned U.S. economist Larry Summers said last October that “we’ve got the most complex, disparate, and cross-cutting set of challenges that I think I can remember in the 40 years I’ve been following this stuff.” This...more

New Legislative Changes for Saskatchewan Potash Sector

Potash is a critical mineral used as a replenishing agricultural fertilizer. As a result, millions of farmers around the world depend on potash. The Canadian province of Saskatchewan is the world's largest potash producer,...more

Canada and the Digitalization of Money: Key Takeaways from a Virtual Workshop of International and Canadian Experts

Key Takeaways from a Virtual Workshop of International and Canadian Experts - Canada and the Digitalization of Money is a report of a virtual conference of international and Canadian experts, organized by Bennett Jones and...more

ESG and Institutional Investors: Part Two

Bennett Jones recently hosted a two-part webinar series on ESG and institutional investors. The first session looked at their role in ESG, private markets and investment, how risks and opportunities are being assessed in the...more

ESG and Institutional Investors: Part One

Bennett Jones recently hosted a two-part webinar series on ESG and institutional investors. The first session looked at their role in ESG, private markets and investment, how risks and opportunities are being assessed in the...more

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

On February 18, 2021, the Supreme Court of Canada announced that it will not hear the transfer pricing tax appeal involving the Government of Canada and Cameco Corporation. Cameco was previously successful in both the Tax...more

Transfer Pricing in the Time of COVID-19

Many Canadian businesses have closed the books on their 2020 fiscal year, having faced an unprecedented economic shock wrought by the pandemic. 2020 fiscal year results will undoubtedly be affected, in many cases to the...more

Me Too Defeats You Too in Tax Court

The Me Too movement of the last few years and recent worldwide protests sparked by George Floyd's killing have focused welcome attention on combatting gender and racial discrimination and harassment. A recent Tax Court of...more

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

The COVID-19 pandemic has resulted in the imposition of travel restrictions by governments and businesses. While such restrictions are no doubt valuable in "flattening the curve", they do, amongst other things, pose...more

The Resilience and Agility of Women in Leadership

I recently moderated a panel of three inspiring women leaders from the Canadian Armed Forces (CAF), who spoke candidly about their career challenges and triumphs. The discussion was part of the second annual True Patriot Love...more

New GST/HST Rules Enacted for Fund Management Fee Arrangements

On December 13, 2018, legislation was passed implementing amendments to the Excise Tax Act (Canada) (the “ETA”) first announced in September 2017 affecting GST/HST on management and administrative services provided to private...more

The Canadian Senate to Review Bill C-21 for Enhanced Canada-U.S. Cross-Border Cooperation

On June 20, 2018, Bill C-21, An Act to amend the Customs Act was introduced in the Canadian Senate upon receiving third reading in the House of Commons. If enacted, the Bill will amend the Customs Act to allow the Canada...more

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

The Canada Revenue Agency (CRA) has announced that it will not seek leave to appeal the Federal Court of Appeal's decision in the BP Canada case. This means that the Court's decision to deny the CRA general and unrestricted...more

On the Ice with Artificial Intelligence

Taking Wayne Gretzky's famous advice—"skate to where the puck is going, not where it has been"—will get easier for businesses that embrace artificial intelligence (AI). That's the conclusion I drew from a sold-out event...more

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

The Federal Court of Appeal has limited the Canada Revenue Agency's (CRA) access to tax accrual working papers that reveal a taxpayer's uncertain tax positions. This case is an important one for every company that has audited...more

Is Your Customs Compliance BEPS Ready?

2016 was the first year of the new transfer pricing reporting regime called Country-by-Country Reporting (CbCR). It will be a major new tool for revenue authorities and will undoubtedly lead to greater audit activity and more...more

What Trump’s Tax Plan Means For Canada

The election of Donald Trump combined with Republican control of Congress means that U.S. tax reform has suddenly gone from totally impossible to highly likely. The specifics of that reform are not known but the...more

Tax Uncertainty Hinders Global Growth: Business Survey Launched

Businesses are invited to participate in an international survey from the OECD to measure the impact of tax uncertainty on their investment decisions. Companies have until December 16 to participate in a confidential...more

Tax Court Allows Deduction for Advisory Fees in M&A Transaction

The Tax Court of Canada has recognized in a recent case that “oversight expenses” – notably investment banking and other professional advisory fees for services rendered to boards of directors in their discharge of oversight...more

Key Policy Initiatives from Canada's New Liberal Government You Need to Anticipate

The Canadian election last week (October 19) produced a new government under Liberal Party leader Justin Trudeau. Defying speculation of a minority government, the Liberals won a clear majority, defeating the NDP and Stephen...more

CRA Releases Important Transfer Pricing Guidance on Management Fees and Other Intra-Group Services

CRA recently released a new Transfer Pricing Memorandum (TPM-15) giving detailed guidance on CRA’s audit approach to management fees and other charges for intra-group services, including on allocation keys for indirect...more

Canadian Customs Authority Shifts Gears on Import Duty Refunds

The CBSA has made a long-sought-for change in its policy to allow duty refunds in the event of qualifying downward transfer price adjustments by importers. The change comes on the heels of victory by Bennett Jones in a test...more

Canadian Importers May Now Seek Import Duty Refunds

Since the introduction of the Transaction Value System of customs valuation by Canada on January 1, 1985, the Canada Border Services Agency (CBSA) has maintained a stated policy of denying refund claims of related party...more

1/19/2015  /  Canada , CBSA , Customs , Duties , Importers , Imports

BEPS Tail Shouldn’t Wag Global Investment Dog

I spoke recently on a panel in Tokyo on the future of international tax planning after BEPS (the OECD’s & G20’s Action Plan to counter Base Erosion & Profit Shifting). The panel also featured a senior official at the OECD and...more

11/18/2014  /  BEPS , Canada , G20 , OECD , Tax Planning
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