In 2014-0534671C6, the CRA was asked about its position on D&D Livestock Ltd. v. The Queen 2013 TCC 318. The CRA indicated that it would not hesitate to invoke the GAAR in similar cases involving duplication of tax attributes.
Ken Jiang is a partner in the Vancouver office of Thorsteinssons LLP.
His practice focuses on domestic and international tax planning, with particular emphasis on cross-border corporate structuring, inbound and outbound investment, and residency planning. His clients include individuals,… more »
