A General Anti-Avoidance Rule (GAAR) for the United Kingdom?
Plus ça change, plus c’est la même chose. The United Kingdom is now seriously considering the introduction of a form of GAAR after having relied for years on judicial doctrines of anti-avoidance as...
View ArticleCopthorne Decision to be Released by Supreme Court of Canada on Friday,...
The Supreme Court of Canada announced today that its long-awaited General Anti-Avoidance Rule (GAAR) decision in Copthorne Holdings Limited v. The Queen will be released on Friday, December 16, 2011 at...
View ArticleCrown Wins GAAR Case in the Supreme Court of Canada: Copthorne Holdings Ltd....
On December 16, 2011, the Supreme Court of Canada released its latest General Anti-Avoidance Rule (GAAR) decision in Copthorne Holdings Ltd. v. Canada. The appeal was heard on January 21, 2011 by all...
View ArticleConference on the Copthorne decision at U of T Faculty of Law – January 6, 2012
On December 16, 2011, the Supreme Court of Canada released its much-anticipated decision in Copthorne Holdings Ltd. v. Canada (go here for our blog post on the decision). Next Friday afternoon,...
View ArticlePanel of Tax Experts Debates Impact of Copthorne Decision at Canadian Tax...
On Thursday, January 26, 2012, in the ballroom of the historic Fairmont Royal York Hotel in downtown Toronto, the Canadian Tax Foundation hosted a lively panel discussion on the recent Supreme Court of...
View ArticleArgument concludes in Supreme Court of Canada in trust residence appeal (Garron)
Earlier today, the Supreme Court of Canada heard arguments in the Garron appeal. The reasons for judgment of the Tax Court of Canada and the Federal Court of Appeal, as well as the factum of each...
View ArticleGAAR Did Not Apply In Respect of Capital Gains Allocated to Minor...
On March 21, 2012 the Tax Court of Canada issued judgment in the decision of McClarty Family Trust et al v. The Queen. The Minister of National Revenue (the “Minister”) had applied the general...
View ArticleCRA Rocks the Boat: Garber et al. v. The Queen
“Now then, Pooh,” said Christopher Robin, “where’s your boat?” “I ought to say” explained Pooh as they walked down to the shore of the island “that it isn’t just an ordinary sort of boat. Sometimes...
View ArticleMcIntyre: Not What You Bargained For?
When are the parties to a civil tax dispute bound by agreed facts from a criminal proceeding? This was the question considered by the Tax Court of Canada on a Rule 58 motion made by the taxpayers in...
View ArticleCRA Update: Aggressive Tax Planning
At the Toronto Centre Canada Revenue Agency & Tax Professionals Breakfast Seminar on June 10, 2014, the Canada Revenue Agency (“CRA”) provided an update on selected CRA Compliance Measures in the...
View ArticleTax Court of Canada: The GAAR Does Not Apply to Disallow Deduction of a $5.6...
On October 28, 2011 the Tax Court of Canada released Judgment and Reasons for Judgment of the Honourable Justice Judith Woods in Global Equity Fund Ltd. v. Her Majesty The Queen, 2011 TCC 507. Global...
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