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
This dissertation considers the role of the UK General Anti Abuse Rule ('GAAR') in challenging loan ...
This paper elaborates on the provision on tax abuse in the EU’s Anti Tax Avoidance Directive (‘ATAD’...
The paper uses a consequential perspective to explore the design features of a target-effective gene...
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 ...
This chapter examines the interpretive exercise under the Canadian GAAR, contrasting this interpreti...
The provisions of GAAR are contained in sections 80A to 80L of the Income Tax Act 58 of 1962. The ma...
On October 19, 2005, the Supreme Court of Canada released the first decisions in which it considered...
From a tax policy perspective, tax avoidance creates serious problems by undermining the key objecti...
The decision of the Tax Court of Canada in McNichol v. The Queen represents the first instance in wh...
Rules targeting specific known schemes are not the only tools available in the battle against tax av...
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...
Predictable statutory interpretation helps ensure the reliable operation of contemporary systems of ...
Tax planning, where taxpayers arrange their affairs so as to minimize the resulting tax liability, h...
This dissertation considers the role of the UK General Anti Abuse Rule ('GAAR') in challenging loan ...
This paper elaborates on the provision on tax abuse in the EU’s Anti Tax Avoidance Directive (‘ATAD’...
The paper uses a consequential perspective to explore the design features of a target-effective gene...
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 ...
This chapter examines the interpretive exercise under the Canadian GAAR, contrasting this interpreti...
The provisions of GAAR are contained in sections 80A to 80L of the Income Tax Act 58 of 1962. The ma...
On October 19, 2005, the Supreme Court of Canada released the first decisions in which it considered...
From a tax policy perspective, tax avoidance creates serious problems by undermining the key objecti...
The decision of the Tax Court of Canada in McNichol v. The Queen represents the first instance in wh...
Rules targeting specific known schemes are not the only tools available in the battle against tax av...
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...
Predictable statutory interpretation helps ensure the reliable operation of contemporary systems of ...
Tax planning, where taxpayers arrange their affairs so as to minimize the resulting tax liability, h...
This dissertation considers the role of the UK General Anti Abuse Rule ('GAAR') in challenging loan ...
This paper elaborates on the provision on tax abuse in the EU’s Anti Tax Avoidance Directive (‘ATAD’...
The paper uses a consequential perspective to explore the design features of a target-effective gene...