Following on the heels of last month’s SCC decision in Lipson v. Canada, Quebec’s Finance Ministry has announced plans to implement further legislative measures to curb aggressive tax planning. Its Working Paper on Aggressive Tax Planning (Document de consultation des planifications fiscales agressives) can be found here. Among its more interesting proposals is the plan [...]

My colleague Julian Ho has already provided a succinct summary of last Thursday’s Supreme Court decision in Lipson v. Canada, 2009 SCC 1, so today I thought I’d comment briefly on the general anti-avoidance rule (GAAR) and the Court’s adoption of a purposive approach in determining whether a transaction or series of transaction is abusive. [...]

Yesterday, the SCC released their first decision of the new year – a decision which may have broad implications on the tax planning of many Canadians. The case, Lipson v. Canada, 2009 SCC 1, deals with the legality of a set of transactions which culminated in the deduction of mortgage loan interest payments for personal [...]

In a peculiar coincidence, or perhaps as a way of joining in all the April tax filing fun, the SCC on Wednesday heard Earl Lipson, et al. v. Her Majesty the Queen, et al. (32041), a case about the legal limits of tax avoidance within Canada’s ‘General Anti-Avoidance Rule’ (GAAR) under the Income Tax Act, [...]