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Tax memo: New Tax Court of Canada rulings on GAAR—1207192 Ontario Limited and Triad Gestco
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On September 7, 2011, the Tax Court of Canada (TCC) released its decision in 1207192 Ontario Limited v. The Queen, 2011 TCC 383. The 1207192 case is the second recent TCC decision dealing with the application of the general anti-avoidance rule (GAAR) in section 245 of the Income Tax Act (the Act) to similar planning. The other case is Triad Gestco Ltd. v. The Queen, 2011 TCC 259, released on July 12, 2011. An appeal has been filed in the Triad Gestco case.
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- Elizabeth Johnson
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Elizabeth Johnson, LLB, LLM
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