Category: Tax Avoidance

Budget 2019: Intensifying the fight against tax evasion and new risks for tax professionals

Published by Greg DelBigio, Q.C. & Jennifer Flood

In Budget 2019, the federal government continues to bolster its tools and resources to detect and prosecute tax evasion and money laundering. These proposals are relevant both to those who do not pay the amount of tax the law requires,…

Federal Court of Appeal Releases its decision in Univar Holdco Canada ULC. v. H.M.Q. 2017 FCA 207

Published by Leonard Gilbert

On October 13, 2017, the Federal Court of Appeal released its decision in Univar Holdco Canada ULC. v. H.M.Q. 2017 FCA 207 (“Univar”), overturning the trial decision at the Tax Court of Canada (2016 TCC 159). The judgment contained…

Of Gaps and the GAAR

Published by Thorsteinssons LLP

Many tax planning transactions fall within the definition of “avoidance transaction” in subsection 245(3) of the Income Tax Act and as such are subject to review under the general anti-avoidance rule (GAAR). Equally, many of the transactions that are reviewed…