Since the creation of the Income Tax Act ("ITA"), there have been taxpayers trying to avoid taxes in any manner possible. Although taxpayers are free to arrange their matters in the most tax-efficient way, there is a line between "tax efficient" and "tax abusive" planning. The General Anti-Avoidance Rules (the "GAAR"), as defined in section […]
Introduction Insolvency judgements from Canada’s highest court are relatively rare. The Supreme Court of Canada (“SCC”) has decided only six since 2015. The most recent of these decisions, 9254-9186 Quebec inc. v. Callidus Capital Corp., 2020 SCC 10 [Bluberi], is not only rare, but also timely. The adverse impact of COVID-19 on the global and […]
The Ontario, Saskatchewan, and Alberta Courts of Appeal disagree about the application of the national concern branch of the federal peace, order, and good government (“POGG”) power. This disagreement can be resolved through a proper characterization of the purpose of the Greenhouse Gas Pollution Pricing Act, SC 2018, c 12, s 186 [GGPPA]. All three […]