Published: May 13, 2025
In April 2025, the Federal Court of Appeal (FCA) delivered its judgment on Total Energy Services Inc. v HMK, 2025 FCA 77, upholding the decision of the Tax Court of Canada in 2024 TCC 12 in February 2024. This case affirms the application of the general anti-avoidance rule (GAAR) under section 245 of the Income Tax Act (ITA) in disallowing loss-trading transactions.
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