Archives - November 2017

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  Univar Holdco Canada v. R. – FCA: FCA rejects Tax Court’s odd interpretation of GAAR

  Nov 14, 2017 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Corporate Tax
  • Federal Income Tax

  Précis: This case dealt with the application of the general anti-avoidance rule (the “GAAR”) to certain transactions that would otherwise allow a non-resident person, immediately following an arm’s length acquisition of control of a Canadian corporation, to extract surplus from that corporation (which had accumulated prior to its acquisition of control) without triggering a dividend under section 212.1 of the Income Tax Act (the “Act”).
  Univar Holdco Canada v. R. – FCA: FCA rejects Tax Court’s odd interpretation of GAARREAD MORE »