Aggressive Tax Planning Schemes, Specially Those Designed by Third Parties, will Annoy CRA – Canada v. Microbjo Properties Inc.
Introduction - When Tax Planning Crosses the Line: Lessons from…
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Federal Court of Appeal reaffirms that tax efficiency alone does not equate to abuse under GAAR: Canada v. Quebecor Inc., 2025 FCA 207
Introduction: GAAR is not a licence to infer limits Parliament…
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GAAR and Corporate Restarts: Madison Pacific Properties Inc. v. Canada, 2025 FCA 20
Introduction – GAAR and the Use of Corporate Losses The…
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A Canadian Tax Lawyer’s Case Commentary on Magren Holdings Ltd. v Canada, 2024 FCA 202: The Application of General Anti-Avoidance Rule (GAAR) on Capital Dividends
What is the General Anti-Avoidance Rule (GAAR) in the Canadian…
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Federal Court of Appeal Overturns GAAR Assessment on the Existence of Alternative Transactions, Leading to No Violation Tax Abuse or Tax Avoidance of GAAR: 3295940 Canada Inc. v The King
Federal Court of Appeal Quashes GAAR Assessment by the CRA…
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Supreme Court of Canada applies GAAR (General Anti Avoidance Rule) in Deans Knight Income v. Canada, Dismissing Taxpayer’s Appeal
Introduction Deans Knight GAAR decision The highlight of the Supreme…
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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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