Category: Tax Avoidance

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…