This content is from: Canada

Is the disclosure ruling in Birchcliff a ray of light for Canadian taxpayers in GAAR disputes?

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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