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Federal Court Of Appeal Strikes Down CCPC Continuance Planning Under GAAR In Canada V. DAC Investment Holdings Inc: Guidance From Canadian Tax Lawyer
On February 20, 2026, the Federal Court of Appeal (FCA) released its decision in Canada v. DAC Investment Holdings Inc. (DAC), 2026 FCA 35, overturning the Tax Court of Canada’s (TCC) ruling that a corporate continuance used to exit the Canadian-controlled private corporation (CCPC) regime did not amount to abusive tax avoidance.
Canada Tax
RS
Rotfleisch & Samulovitch P.C.
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Income Tax

Curated
Federal Court Of Appeal Strikes Down CCPC Continuance Planning Under GAAR In Canada V. DAC Investment Holdings Inc: Guidance From Canadian Tax Lawyer
On February 20, 2026, the Federal Court of Appeal (FCA) released its decision in Canada v. DAC Investment Holdings Inc. (DAC), 2026 FCA 35, overturning the Tax Court of Canada’s (TCC) ruling that a corporate continuance used to exit the Canadian-controlled private corporation (CCPC) regime did not amount to abusive tax avoidance.
Canada Tax
RS
Rotfleisch & Samulovitch P.C.
See more

Transfer Pricing

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