CRA describes interpretation of s.95(6)(b) post Lehigh

In 2014-0550441C6, the Canada Revenue Agency set out how the Federal Court of Appeal’s decision in the Lehigh Cement case affects the CRA’s interpretation of subsection 95(6)(b) of the Income Tax Act (Canada). “CRA accepts that 95(6)(b) is generally targeted at transactions intended to manipulate the status of a non-resident corporation for the purposes of subdivision i, Division B of Part I of the Act.”

Prepared by: E. Rebecca Potter

Becky Potter is a seasoned tax litigator and a partner based out of the firm’s Toronto office. Becky brings a strategic and practical approach to tax disputes, and is known for her ability to distill complex technical tax matters down… more »

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