Add to ORKGThe “misuse or abuse” exception under subsection 245(4) of the Income Tax Act draws the line between acceptable and unacceptable tax avoidance. As a “safety valve” or “relieving provision,” this exception has proved to be the “most crucial and controversial single factor in the application of the GAAR.” Whether a transaction that lacks economic substance is subject to the general anti-avoidance rule (GAAR) is the question considered in this chapter
Although a general anti-avoidance rule (GAAR) being enacted within a country is becoming increasingl...
This article argues that statutory general anti-avoidance or anti-abuse provisions (GAARs) are an es...
This article argues that statutory general-anti avoidance or anti-abuse provisions (GAARs) are an es...
The “misuse or abuse” exception under subsection 245(4) of the Income Tax Act draws the line between...
The general anti-avoidance rule (GAAR) in section 245 of the Income Tax Act is about drawing a line ...
The paper uses a consequential perspective to explore the design features of a target-effective gene...
This paper elaborates on the provision on tax abuse in the EU’s Anti Tax Avoidance Directive (‘ATAD’...
The primary aim of this article is to question whether the general anti-abuse rule (GAAR) of Anti-Ta...
This paper addresses a principle in international taxation that has long been a subject of controver...
The decision of the Tax Court of Canada in McNichol v. The Queen represents the first instance in wh...
From a tax policy perspective, tax avoidance creates serious problems by undermining the key objecti...
The main research questions of the paper, therefore, are shaped in line with all these developments:...
I support the initiative to revisit the GAAR for purposes of making it more effective. I find the Mo...
A General Anti-Avoidance Rule (GAAR) is currently included in many tax systems to counteract the us...
General Norm of Anti-Avoidance in Corporation Income Tax: Concept and Assessment The main topics tha...
Although a general anti-avoidance rule (GAAR) being enacted within a country is becoming increasingl...
This article argues that statutory general anti-avoidance or anti-abuse provisions (GAARs) are an es...
This article argues that statutory general-anti avoidance or anti-abuse provisions (GAARs) are an es...
The “misuse or abuse” exception under subsection 245(4) of the Income Tax Act draws the line between...
The general anti-avoidance rule (GAAR) in section 245 of the Income Tax Act is about drawing a line ...
The paper uses a consequential perspective to explore the design features of a target-effective gene...
This paper elaborates on the provision on tax abuse in the EU’s Anti Tax Avoidance Directive (‘ATAD’...
The primary aim of this article is to question whether the general anti-abuse rule (GAAR) of Anti-Ta...
This paper addresses a principle in international taxation that has long been a subject of controver...
The decision of the Tax Court of Canada in McNichol v. The Queen represents the first instance in wh...
From a tax policy perspective, tax avoidance creates serious problems by undermining the key objecti...
The main research questions of the paper, therefore, are shaped in line with all these developments:...
I support the initiative to revisit the GAAR for purposes of making it more effective. I find the Mo...
A General Anti-Avoidance Rule (GAAR) is currently included in many tax systems to counteract the us...
General Norm of Anti-Avoidance in Corporation Income Tax: Concept and Assessment The main topics tha...
Although a general anti-avoidance rule (GAAR) being enacted within a country is becoming increasingl...
This article argues that statutory general anti-avoidance or anti-abuse provisions (GAARs) are an es...
This article argues that statutory general-anti avoidance or anti-abuse provisions (GAARs) are an es...