Two cases from the Federal Court of Appeal in Canada have opened the door for greater scrutiny of trust arrangements. This new case law, coupled with an emboldened Canada Revenue Agency, will probably mean more pressure on taxpayers that set up these vehicles to avoid income tax. Erin Kelechava looks at the way these cases will affect tax planning and how they may be illustrative of a broader trend against tax avoidance in Canada.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems