Copthorne Holdings Ltd v Canada: "Series of Transactions" Under the GAAR
A fundamental tenet of Canadian tax law, as stated in Commissioners of Inland Revenue v Duke of Westminster, [1936] AC 1 (HL), is that a taxpayer is entitled to make any lawful arrangement that he or she sees fit in order to reduce his or her liability to tax. The General Anti-Avoidance Rule ("GAAR"), at section […]