The GAAR applied: Deans Knight Income Corp v Canada
In Deans Knight Income Corp. v Canada, 2023 SCC 16, (“Deans Knight”) the Supreme Court of Canada (“SCC” or “the Court”) dismissed the taxpayer’s appeal, holding that the General Anti-Avoidance...
Tagged: Tax law
Equity Cannot Relieve Tax Mistakes
Introduction The Supreme Court of Canada (“SCC”) bifurcated 8-1 in Canada (Attorney General) v Collins Family Trust, 2022 SCC 26 (“Collins”) with Brown J writing for the majority and Côté...
General Anti-Avoidance Rule to the Rescue: Canada v Deans Knight Income Corp.
The Supreme Court of Canada (“SCC”) granted leave to Deans Knight Income Corporation (“Deans Knight”) on March 10th, 2022 to appeal a Federal Court of Appeal (“FCA”) decision from August...
Arm’s Length Transaction or Not? Canada v Loblaw Financial Holdings Inc.
Introduction In Canada v Loblaw Financial Holdings Inc., 2021 SCC 51 [“Loblaw”], the Supreme Court of Canada (“SCC”) examines “one of the most complex tax schemes, with hundreds of definitions,...
