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- Title
THE MINISTER GOES SHOPPING: GAAR AND CANADA'S TAX TREATIES.
- Authors
Wentzell, David
- Abstract
The article analyzes the decision of the Tax Court of Canada in the case involving MIL (Investments) SA that was able to avoid Canadian tax through its bilateral tax treaties. The minister assessed MIL for tax on series of transactions with Diamond Fields Resources Ltd. The general anti-avoidance rule was amended in 2005 to add reference to tax treaty provisions. The judge ruled that there was an anti-abuse rule inherent in the treaty.
- Subjects
CANADA; TAX court decisions; ACTIONS &; defenses (Law); DOUBLE tax agreements; MIL (Investments) SA; DIAMOND Fields Resources Inc.
- Publication
Canadian Tax Journal / Revue Fiscale Canadienne, 2007, Vol 55, Issue 1, p136
- ISSN
0008-5111
- Publication type
Article