The Canada Revenue Agency (CRA) must disclose to taxpayers how specific provisions of the Income Tax Act (Act) were abused whenever it applies the general anti-avoidance rule (GAAR) in a dispute, the Tax Court of Canada has ruled. And advisers say taxpayers could benefit from this information in future GAAR cases.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap