Copthorne’s legacy: The future of Canada’s GAAR

February 01, 2012

Taxpayers awaited the Supreme Court of Canada’s (SCC) verdict in Copthorne with anxious anticipation in December, hoping for a roadmap to help ensure they don’t fall foul of the country’s GAAR. Joe Dalton investigates what the decision means for tax planning and how taxpayers can undertake an action with no business purpose, purely to achieve a tax benefit, without this being seen as an abuse of the Income Tax Act.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & bottom lb ros

More from across our site

Direct Tax

Irvine, CA, USA - May 6, 2022: Exterior view of Baker Tilly's office in Irvine, California. Baker Tilly US, LLP is a public accounting and consulting firm headquartered in Chicago, Illinois.

Baker Tilly Netherlands to receive private equity boost

Mid-market European private equity house Inflexion, which also backs law firm DWF, has agreed to acquire a minority stake in the Dutch tax advisory firm

Tom Baker, January 23, 2025

Direct Tax

Bilateral APAs ‘not as simple’ as before: Baker McKenzie hire

Donald Trump’s inauguration, pillar two, APAs and TP were all up for discussion as ITR spoke to Baker McKenzie’s two newly minted US partners

Sam Sholli, January 23, 2025

Direct Tax

Co-sourcing in tax: a growing trend with pillar two

In-house teams that want a balance of internal control and external expertise for pillar two should seriously consider co-sourcing models, Russell Gammon of Tax Systems argues

Russell Gammon, January 22, 2025

Direct Tax

Trump: OECD’s pillar two ‘no force or effect’ in US

The OECD has vowed to continue working with the US despite the president effectively pulling the country out of the organisation’s global minimum tax deal

Sam Sholli, January 21, 2025

Direct Tax

Exploring the tax classification of non-Dutch entities in 2025

Norton Rose Fulbright highlights a Brazilian investment fund as a practical example of how new Dutch tax rules will require significant attention from foreign companies

Bart Le Blanc , January 20, 2025

Direct Tax