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

A taxing week: Deloitte’s culture is about to face a tough test

As the firm embarks on a major shakeup of its EMEA partnerships, some staff will be watching nervously

Ed Conlon, March 06 2026

Direct Tax

Close up shake hands, Considering buying a home, investing in real estate. Broker signs a sales agreement. agent, lease agreement, successful deal.

This week in tax: Ryan acquires property tax consulting firm in US

The buyout of Hucke and Associates continues Ryan’s streak of firm acquisitions; in other news, a UK appeal against VAT on private school fees was dismissed

Sam Sholli, March 06 2026

Direct Tax

Iran conflict: UAE tax teams operating as usual despite disruption

Tax teams are responding to usual client demand in the region, albeit with increased working from home flexibility, local sources indicate

Tom Baker, March 05 2026

Indirect Tax

This month in indirect tax: Tariff refund delays may cost US taxpayers $700m per month

A 120-plus-day delay to refunds would cost taxpayers almost $3bn in additional interest, the Cato Institute warned; plus indirect tax updates from February

Sam Sholli, March 04 2026

Direct Tax

UK pound,money of United kingdom close up on white, Pound UK not

US pillar two side-by-side deal will cost UK £700m per year

The Office for Budget Responsibility’s pessimistic pillar two forecast accompanied the UK chancellor’s muted Spring Statement, dubbed ‘as dull as possible’ by one adviser

Tom Baker, March 03 2026

Direct Tax

Creative destruction and digital tax: reflecting on the 2025 Nobel Prize

Digital tax reform is dissolving the old ‘temporal buffer’, forcing systems, institutions, and professionals to adapt as real-time reporting reshapes governance, capability, and compliance

Nitin Agarwal, March 03 2026

Podcasts

Editable TT 640x360 article-thumbnail (2).png

Taxing Times: introducing ITR’s new monthly podcast

Our first instalment features analysis of Deloitte’s landmark EMEA merger, Donald Trump’s Supreme Court tariff showdown and Venezuela’s tax evolution

Tom Baker, March 02 2026

Direct Tax

‘Potential to raise standards’: mixed adviser reaction to HMRC registration system

While some believe it could have a positive effect on the wider advisory landscape, others argue that HMRC’s ‘red tape’ exercise won’t deter bad actors

Sam Sholli, March 02 2026

Direct Tax

Pillar two is revising global tax competition with a 15% minimum tax rate

A taxing week: Pillar two will prosper despite US side-by-side arrangement

The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos

Paul Monaghan, February 27 2026

Direct Tax

This week in tax: PwC commences legal battle with boutique consultancy founded by ex-COO

The big four firm reportedly sent ‘threatening’ correspondence to Unity Advisory over its hiring of ex-PwC partners; plus tax recruitment news from the week

Sam Sholli, February 27 2026