Tax Dispute Caselaw & Signals

Key Takeaways Loss consolidation transactions attract CRA scrutiny even when they align with Parliament’s design. The mechanical structure rarely drives the dispute – the interpretive record does. Bus...

Key Takeaways The mechanics worked, but the Court focused on whether the reorganization produced a real economic loss or merely a paper one. That distinction shaped the GAAR outcome. The decisive batt...

Key Takeaways CRA challenges often evolve from mechanical to interpretive tests. The decisive factor is not a structure’s mechanics but whether its interpretive elements hold up under scrutiny. Meetin...