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Tax Insights: Gerbro Holdings – TCC did not apply offshore investment fund rules to investment in tax haven

In its recent decision in Gerbro Holdings Company v. The Queen, the Tax Court of Canada (TCC) refused to apply the offshore investment fund tax rules (in section 94.1 of the Income Tax Act (Canada)) to interests held by a Canadian investor in funds based in low- or no-tax jurisdictions—in this case five funds based in the Cayman Islands, the Netherlands Antilles and the British Virgin Islands.

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