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- Title
Copthorne Holdings Ltd. v. The Queen.
- Authors
Kopstein, Robert; Sidhu, Jasmine
- Abstract
The article discusses a court case wherein the Canadian Federal Court of Appeal upheld a Tax Court decision that a share sale involving the appellant was a tax avoidance transaction. In Copthorne Holdings Ltd. versus the Queen, the national revenue minister assessed the appellant based on the principle that the general anti-avoidance rule (GAAR) is applicable to lower the paid-up capital (PUC) of the preferred shares of a non-resident shareholder. The appellant was evaluated for a penalty pursuant to subsection 227(8) of the Income Tax Act.
- Subjects
CANADA; ACTIONS &; defenses (Law); TAX evasion; STOCKS (Finance); SECURITIES industry laws; PUNISHMENT; COPTHORNE Holdings Ltd.; CANADA. Federal Court of Appeals; CANADA. Tax Court
- Publication
Canadian Tax Journal / Revue Fiscale Canadienne, 2009, Vol 57, Issue 3, p563
- ISSN
0008-5111
- Publication type
Article