Author: Vivian Esper

In Canada v Rio Tinto Alcan[1], the Federal Court of Appeal (“FCA”) upheld the Tax Court of Canada (“TCC”) decision[2] confirming, inter alia, the deductibility of certain takeover expenses incurred by Rio Tinto Alcan Inc. (“Alcan”) in its takeover of…

The Tax Court of Canada decision in Lee v The Queen, 2018 TCC 230 clarified the concept of sham in the context of transactions undertaken to give effect to a tax plan. The decision draws a line between tax avoidance…