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 & shared bottom lb ros

More from across our site

Direct Tax

This week in tax: EU mulls pillar two revisions to placate US

The scope of qualifying pillar two tax credits could reportedly be broadened; in other news, hundreds of IRS appeals staff are to resign

Tom Baker, May 02 2025

Transfer Pricing

Bilateral APAs have their moment

For many taxpayers, the prospect of long-term certainty that a bilateral APA offers can override concerns about time, cost and confidentiality

Ralph Cunningham, May 01 2025

Direct Tax

Baker McKenzie picks up former US Treasury deputy Scott Levine

Levine, who served under the Joe Biden administration, led the US’s negotiations on the OECD’s two-pillar solution

Tom Baker, April 30 2025

Direct Tax

Legal Benchmarking Group acquired by Triple Private Equity

The deal to acquire ITR's parent company is expected to complete by the end of May 2025

Tom Baker, April 29 2025

Direct Tax

Meat multinational JBS accused of dodging $442m in taxes

JBS, the biggest meat company in the world, allegedly used Luxembourgian ‘mailbox companies’ to avoid taxes between 2019 and 2022

Tom Baker, April 28 2025

Direct Tax

Australian tax adviser imprisoned for operating while unregistered

Despite the conviction of Jessa Dabalos, the Tax Practitioners’ Board’s investigative work continues with five outstanding PwC scandal probes

Tom Ravlic, April 28 2025

Direct Tax

Female hand with megaphone on white background

Why in-house tax teams should do their own PR

Heads of tax need to push their teams forward as strategic business advisers to add value across their organisations, says Sandy Markwick

Sandy Markwick, April 25 2025

Direct Tax

This week in tax: Elon Musk and Treasury secretary clash over IRS leadership

Scott Bessent reportedly felt undermined by Musk naming Gary Shapley as acting IRS commissioner; in other news, Baker Tilly will combine with a top 15 US firm

Tom Baker, April 25 2025

Transfer Pricing

India’s record APAs a win for government efficiency: experts

The promise of nine years’ tax certainty and a ‘rational and pragmatic’ government process makes APAs a no-brainer, Indian tax advisers tell ITR

Tom Baker, April 24 2025

Transfer Pricing

Fixing Italy’s approach to taxing digital business

Despite garnering significant revenues from multinationals, Italy’s digital services tax presents pressing double taxation issues, say Stefano Simontacchi and Francesco Saverio Scandone of BonelliErede

Stefano Simontacchi , April 23 2025