Published: March 23, 2020
Last Updated: April 13, 2020
GAAR assessment cannot give rise to penalties for non-compliance with the technical sections
In the recent Tax Court of Canada decision in Copthorne Holdings Ltd. v The Queen 2002-1316(IT)G the court held that a general anti-avoidance rule (GAAR) assessment under section 245 of the Income Tax Act cannot give rise to penalties for non-compliance with the technical sections of the Act.
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