Tax

We provide strategic, practical tax advice that simplifies complexity, minimizes risk, and maximizes value in every transaction.
Key Contacts
Bauer ThomasNijhawan AnuWang Julia
Writing on form

Overview

One of the main goals in a corporate transaction is to maximize profit while minimizing risk. This takes sound tax advice, given the complexities of the Canadian tax system and the range of rules and laws that govern domestic and foreign companies. Bennett Jones' corporate tax practice provides sophisticated tax planning advice and creative, incisive approaches to stewarding tax-efficient transactions and solving tax controversies (read more about our Tax Litigation & Dispute Resolution practice).

Tax is an essential element in helping clients maximize the return on their investments and operations. With that in mind, our tax lawyers are brought into transactions at the outset, and play a strategic role in the structuring and negotiation of mergers, acquisitions, divestitures, and all range of business ventures.

Our tax lawyers have a broad range of significant experience on both the Canadian and cross-border aspects of transactions in the resource, manufacturing, financial services, communications, technology, real estate, transportation, power (conventional and alternative) sectors. We advise private equity investors, pension funds and sovereign wealth funds and have been involved in the conversion of income trusts and royalty funds to corporate form.

,,The entire tax team is very strong, both technically and from a personality standpoint.,,

What Clients Say

Our experience encompasses the implementation of tax-efficient equity incentive plans, including stock options, restricted share trusts and phantom units (SARs, RSUs and DSUs). We also advise clients on employee ownership trust (EOT) structures and the opportunities for succession planning and ownership transition, having implemented one of the first EOTs in Canada. 

Our practice includes all aspects of sales tax, GST, anti-dumping and other trade and commodity taxes. This commodity tax expertise is brought to bear both in connection with transactions involving cross-border flows of manufactured goods, financial services and commodities, and in tax controversy work.

As part of our practice we deal with the Canada Revenue Agency and international tax authorities in obtaining advance income tax rulings. We are called upon frequently to advise and provide opinions on proposed changes to both federal and provincial tax legislation and to advise on the handling of tax audits, and litigate tax reassessments. We also advise corporations in connection with stock option and other equity compensation arrangements.

Members of our group are active participants and leaders in tax organizations such as the Joint Committee on Taxation of the Canadian Bar Association and the Canadian Institute of Chartered Accountants, the International Fiscal Association, the Canadian Tax Foundation and the Canadian Petroleum Tax Society. Many of our lawyers are recognized as leading practitioners in the area of corporate taxation by Lexpert, Euromoney's guides to the world's leading lawyers and Chambers Global:The World's Leading Lawyers for Business.

Client Work

Canadian Pacific Kansas City
in its historic US$31-billion cash and stock cross-border merger with Kansas City Southern
CoolIT Systems
in its US$270 million sale to KKR
Canadian Utilities
in its restructuring, co-ownership and financing arrangements with Chiniki and Goodstoney First Nations
Canadian Utilities
in the sale of its entire Canadian fossil fuel-based electricity generation portfolio for approximately $835 million, which was completed in three stages
Flexpoint
in a structured investment and strategic partnership in Nettwerk Music Group
Heartland Generation
in its C$658 million sale to TransAlta
Hillcore
in its $392-million acquisition of Thompson Construction Group, based primarily in Edmonton
Hut 8
in its US$1-billion all-stock merger of equals with US Data Mining Group to create one of North America's leading digital asset mining businesses
Loyalty Ventures
in connection with a potential financial restructuring of LVI’s indebtedness
Nippon Steel
in its 2024 C$1.15-billion investment in Elk Valley Resources, a steelmaking coal business to be spun out as an independent public company from Teck Resources
Osisko
in its C$600-million 50-50 joint venture with a Gold Fields affiliate for ownership and development of the Windfall gold project, located in Abitibi, Eeyou Istchee James Bay
Pine Cliff
in its 2023 C$100-million acquisition of a privately held oil and natural gas producer by way of takeover bid
Questrade
in its acquisition of Flexiti Financial, a Canadian point-of-sale financing business, from CURO Group Holdings
Repsol Oil
in its US$468-million sale of all partnership interests of Repsol Canada Energy Partnership to Peyto Exploration & Development
Riverstone
in Lithium Royalty's pre-closing reorganization and C$150-million initial public offering, the largest Canadian IPO of 2023
Secure Energy
in its C$1.075-billion asset sale of certain waste management facilities
Vale
in connection with a spin-out by VCL's parent, Vale S.A.
Grantbook
in its implementation of an employee ownership trust structure under the Income Tax Act (Canada)

Cresco Labs
in its US$2-billion acquisition of Columbia Care 
Cresco Labs
in its acquisition of Tryke Companies, including the Reef Dispensary Portfolio, for US$252.5 million for Tryke operating assets plus US$30 million for Tryke real estate assets
Excellon Resources
in its $32.3-million acquisition of Otis Gold Corp by way of a Statutory Plan of Arrangement under the BCBCA
Canadian Pacific Railway
in its public offering of $300-million aggregate principal amount of 3.05% notes due 2050
Canadian Pacific Railway
in its public offering of US$500-million aggregate principal amount of 2.050% notes due 2030
United Active Living
in matters related to ownership and operations of assisting living housing projects.
Kissner Group Holdings
completed its acquisition of NSC Minerals, a market-leading provider of salt products in Western Canada and the North Central United States, from an investor group led by Altas Partners
Katanga Mining
in its $7.6-billion rights offering financing backstopped by Glencore to fund debt repayment to Glencore
Inuvialuit Development Corporation
in the merger of Canadian North and First Air (owned by Makivik Corporation), to create a Inuit-owned unified northern Canadian airline
Northern Metalic Sales
in its sale to affiliates of Side Management
Holloway Lodging Corporation
in the acquisition by Clarke of all of the issued and outstanding common shares of Holloway that it does not currently own by way of statutory plan of arrangement
Devon Canada Corporation and Devon Canada Crude Marketing Corporation
in their approx. $3.8-billion sale of substantially all of their assets to Canadian Natural Resources Limited
Zedi
in the sale of its software and automation businesses to affiliates of Emerson Electric
Bellatrix
in its recapitalization pursuant to the CBCA
Broadridge Financial Solutions
in its approximately US$300-million acquisition of RPM Technologies
CIP Capital Management
in its acquisition of People 2.0
BSM Technologies
in its approximately $117.3-million sale to Geotab by way of plan of arrangement
ATCO
completes private placement of $200M fixed-to-floating subordinated notes
Algonquin Power Utilities
registered fixed to floating subordinated notes southbound MJDS offering
Ad Hoc Committee of Unsecured Debtholders
in the US$4 billion recapitalization of Concordia International
Baker Technologies
in its business combination with Santé Veritas Holdings, Briteside Holdings and Sea Hunter Therapeutics

Recognitions

ITR Americas Tax Awards

2022 Canada Indirect Tax Firm of the Year
2022 Impact Deal of the Year, Canadian Pacific Railway's historic US$31 billion merger with Kansas City Southern

Chambers Canada
Ranked, Tax

Chambers Global
Band 2, Tax

The Legal 500: Canada
Ranked, Tax

Canadian Legal Lexpert Directory
Most Frequently Recommended, Corporate Tax (Calgary)
Consistently Recommended, Corporate Tax (Vancouver)
Repeatedly Recommended, Corporate Tax (Toronto)
World Tax
Ranked (Tier 1), Tax Controversy
Ranked (Tier 2), Transactional Tax
Ranked (Tier 2), Tax

Explore Our Services

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We help businesses manage transfer pricing risks and opportunities with integrated tax and customs strategies, effective compliance, and strong advocacy in audits and disputes.
Tax Litigation & Dispute Resolution

Tax Litigation & Dispute Resolution

We help clients resolve complex tax disputes efficiently and strategically, from CRA audits to appeals before Canada’s highest courts.
Bauer Thomas

Thomas A. Bauer

Partner   •   Co-Head of Tax Department

Nijhawan Anu

Anu Nijhawan

Partner  •   Co-Head of Tax Department

Article

Bennett Jones on Tax Disputes: June 2025

June 18, 2025
Edwin G. Kroft KCAntoine MesservierAndrew Young
Edwin G. Kroft KC, Antoine Messervier & Andrew Young
Article

Bennett Jones on Tax Disputes: April 2025

April 4, 2025
Edwin G. Kroft KCAntoine Messervier
Edwin G. Kroft KC & Antoine Messervier
Your Guide to Legal Solutions: Tax

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The Bennett Jones Story

At Bennett Jones, legal solutions are our starting point. What drives us forward is knowing our clients inside and out—their ambitions, obstacles and success metrics.

For more than a century, we have shaped outcomes that matter in business, in law and in the broader Canadian landscape. And our commitment extends beyond legal matters: we invest deeply in the communities in which we live and work.