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Searching Content indexed under Income Tax by Brian Kearl ordered by Published Date Descending.
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GARR Case Comment: Collins & Aikman (TCC) A More Stringent Test for Abusive Tax Avoidance
In Collins & Aikman Products Co. v. R., the appellant, a U.S. resident corporation ("USCO"), realized a tax-exempt capital gain on the exchange of its shares in its wholly-owned subsidiary, Collins & Aikman Holdings Ltd. ("CAHL"), for a single share of a new Canadian holding company ("CanHoldco").
Canada
25 May 2010
2
Mr. Lipson Goes To Ottawa: Clarifying Interest Deductibility But Not The General Anti-Avoidance Rule
On January 8, 2009 the Supreme Court of Canada released its decision in Lipson.
Canada
16 Feb 2009
3
The General Anti-Avoidance Rule: Are We Moving Away From Consistency, Certainty And Predictability
The General Anti-Avoidance Rule (the "GAAR"), contained in section 245 of the Income Tax Act (Canada) (the "Act"), is a provision which allows the Canada Revenue Agency ("CRA") to redetermine the tax consequences of a transaction(s) entered into by a taxpayer in an effort to deny the tax benefit(s) otherwise enjoyed by the taxpayer as a result of entering into the impugned transaction(s).
Canada
2 Jul 2008
4
Moving To The United States: Tax Consequences And Planning Opportunities
Moving to the United States may raise all sorts of concerns for individuals resident in Canada, not the least of which are the potential tax consequences to such a move.
Canada
20 Jun 2008
5
The Unintended Consequences Of Subsection 256(9)
The lncome Tax Act (Canada) (the "Act"), contains all manner of "shoals and traps", which may result in unintended tax consequences to the unaware, and in some cases to the aware.
Canada
21 Apr 2008
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