Three cases involving application of the general anti-avoidance rule (GAAR), at the Canadian Federal Court of Appeal (FCA), to deny taxpayers a capital or income loss, based on the distinction between a genuine capital loss and a loss on paper, have been seen in just three weeks. All have been denied.
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Two months since EU political agreement on pillar two and few member states have made progress on new national laws, but the arrival of OECD technical guidance should quicken the pace. Ralph Cunningham reports.