The Tautology of Canada’s GAAR: A Tax Haven for Uncertainty
Posted March 26 10 at 2:50 am
I. Introduction:
Since 1988, Canadian tax pundits commonly retreat from opining on whether the Minister of National Revenue will successfully reassess any given taxpayer benefits arising from any novel series of tax avoidance transactions, with the ever-elusive, potentially omnipotent, and philosophically teleological, general anti-avoidance rule, [hereinafter, “GAAR”]. GAAR supplements numerous other specific anti-avoidance provisions [hereinafter, “SAAPs”] of the Income Tax Act and, therefore, is a provision of last resort after the ...
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EMERGENCY AID FOR 500 HAITIANS
Posted March 04 10 at 2:21 am
Toronto/New York –Help to Eliminate Disease and Addiction Canada [“HEDAC”], is proud to announce the signing of an historic agency agreement with Housing Works. This agreement marks HEDAC’s ongoing commitment to Canadian donors, to the Canadian Government, and to the world, to effect ever-increasing, large-scale, transborder donations of essential life-saving medicines to people living with HIV and AIDS globally. By forming a strategic alliance with the leading U.S.-based AIDS charity, ...
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Tax Tips Series
Posted February 17 10 at 6:06 am
Killing two taxes with one RPGA
RPGs are “rocket propelled grenades”. As powerfully and precise as they may penetrate a wall of steel, not even they can pierce the almighty corporate veil, which supposedly separates the legal personalities of both shareholder and the corporate person being “held”. What can pierce the corporate veil, however, are the tax benefits that accrue to shareholders who corporately “bonus out” and then personally participate in ...
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