Canadian Lawyer Analysis – The Supreme Court of Canada Holds that Tax Treaty Shopping Does Not Constitute Abuse Within the Meaning of the General Anti-Avoidance Rule (Canada v. Alta Energy Luxembourg S.A.R.L.)
Two Spectrums in the Canadian Tax Planning Behaviour There are…
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Canadian Tax Lawyer Analysis of a GAAR Case
Rogers Enterprises (2015) Inc. v The Queen – Canadian tax…
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CHR Investment Corporation v The Queen – GAAR – (Subsection 245(2)) of the Income Tax Act and the Need for Clarify on Policy Application and Analysis
The Legal Background & Section 245’s GAAR Policies The general…
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General Anti Avoidance Rules
GAAR assessment cannot give rise to penalties for non-compliance with…
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Tests for Application Of GAAR
Application of the General Anti Avoidance Rule (GAAR) involves three…
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Split Up Corporation By Shareholders Not Subject to GAAR
Split up of a corporation by shareholders did not violate…
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Gaar Assessment
GAAR assessment cannot give rise to penalties for non-compliance with…
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Corporate Amalgamation Deemed an Avoidance Transaction – A Canadian Tax Lawyer’s Perspective
Introduction – The Amalgamation and the Alleged Tax Avoidance Transaction…
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Gaar Court Decisions
Introduction The General Anti-Avoidance Rule (GAAR), set out in Section…
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Tax Avoidance & Tax Planning – General Anti-Avoidance Rule
Tax Avoidance& Tax Planning – General Anti-Avoidance Rule – Canadian…
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