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Edwin G. Kroft KC

Tax Litigation Lawyer at Bennett Jones

Partner

Andrew Young

Tax Lawyer at Bennett Jones Toronto

Associate

Spencer Brown

Tax Lawyer at Bennett Jones Calgary

Issue 35 of Bennett Jones on Tax Disputes, published on <a rel="noopener noreferrer" rel="noopener noreferrer" href="https://www.gettaxnetpro.com/" target="_blank">Taxnet Pro</a> by Thomson Reuters, features an overview of recent cases of note and cases under appeal. This issue contains two articles from members of Bennett Jones' tax group. <a href="/People/B/Brown-Spencer">Spencer Brown</a> discusses the most recent Canada Revenue Agency guidance about the application of the general anti-avoidance rule and <a href="/People/Y/Young-Andrew">Andrew Young</a> comments on the recent Tax Court of Canada decision in Martin v the King, 2024 TCC 153. Issue 35 also contains summaries of recent tax decisions, tables regarding tax appeals and practice directives from the courts.

Bennett Jones on Tax Disputes February 2025

Bennett Jones on Tax Disputes: February 2025

Jared A. Mackey

Corporate Tax Lawyer at Bennett Jones Calgary

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

The <a href="https://www.budget.canada.ca/2023/home-accueil-en.html">2023 Canadian Federal Budget</a>, released March 28, 2023, provides particulars on the proposed new two percent tax on share buybacks and expands the proposal to apply to repurchases of equity by certain trusts and partnerships.

Canada Clarifies and Expands Proposal for Equity Buyback Tax

The federal government's <a rel="noopener noreferrer" rel="noopener noreferrer" href="https://www.budget.gc.ca/fes-eea/2022/home-accueil-en.html" target="_blank">2022 Fall Economic Statement</a>, released on November 3, 2022, introduced a new tax on share buybacks by public corporations in Canada. Under the proposal, which would come into force on January 1, 2024, a two percent corporate-level tax would apply on the "net value" of a corporation's share buybacks.

Canada Proposes New Tax On Share Buybacks

Katherine Booth

Litigation Lawyer at Bennett Jones Vancouver

Nina Butz

Litigation Lawyer at Bennett Jones Toronto

In RateMDs Inc. v. Bleuler, 2025 BCCA 329, the BC Court of Appeal overturned certification of a proposed privacy class action, finding that the plaintiff's novel claims that use of health professionals' names violated their privacy and amounted to commercial exploitation under provincial privacy statutes were bound to fail.

BC Court of Appeal dismisses proposed privacy class action

BC Court of Appeal Dismisses Proposed Privacy Class Action; Finds Use of Professionals' Names Was Not Commercial Exploitation 

William S. Osler KC

Capital Markets, Securities, M&A and Corporate Governance Lawyer at Bennett Jones Calgary

Denise D. Bright

Public and Private Company Financial Transactions and Securities Lawyer at Bennett Jones Calgary

Partner 

Olu Akinniyi

Articling Student

Recent amendments to Alberta&rsquo;s Securities Act strengthen the Alberta Securities Commission&rsquo;s ability to address financial misinformation and protect investors. Enacted through the Financial Statutes Amendment Act, 2025 (No. 2), the changes expand the definition of forward-looking information and grant the ASC new authority to temporarily halt trading where misleading or inaccurate information is being disseminated. While aimed at curbing harmful online promotion, including by &ldquo;finfluencers,&rdquo; the amendments also have important implications for reporting issuers and their disclosure practices.

Alberta Expands ASC Powers to Address Financial Misinformation

Laura James

Corporate Lawyer at Bennett Jones Vancouver

Rebecca Burnand

Corporate Lawyer at Bennett Jones Calgary

Madison Sutherland

Newly released market data out of the US shows the demand for beauty products remained strong in 2025 despite pressure on overall consumer spending. Beauty M&amp;A deal volume in the US decreased slightly this year due to tariff and trade concerns, but analysts are optimistic for a busier 2026 on the dealmaking front.

Whats Shaping MA in the Beauty Industry

Glow and Grow: What's Shaping M&A in the Beauty Industry

Ethan Z. Schiff

Commercial Litigation Lawyer at Bennett Jones Toronto

Maisah Syed

In David v. Loblaw Companies Limited, the Ontario Court of Appeal confirms that a certification denial for failure to plead a cause of action is final and barred by res judicata. Absent narrow exceptions, plaintiffs cannot amend pleadings to relitigate certification and must pursue an appeal.

Ontario Court of Appeal Says that Plaintiffs Cannot Amend Instead of Appeal

Daron K. Naffin

Energy, Environmental/Regulatory and Expropriation Lawyer at Bennett Jones Calgary

Tim Myers

Regulatory, Environmental, Aboriginal and Expropriation Lawyer at Bennett Jones Calgary

Thomas Machell

Regulatory Lawyer at Bennett Jones Calgary

The Alberta Energy Regulator has released new editions of Directive 071 and Manual 026, significantly expanding emergency preparedness and response requirements. This post outlines the key changes, including mandatory Emergency Management Programs, expanded scope across resource sectors, enhanced hazard analysis standards, and what approval holders should do ahead of the February 2, 2026 effective date.

Suzanne Byrne and Spencer Brown on Tax and Trust

From the Same Authors