In Pomerleau c R, 2016 CCI 228, the Tax Court applied GAAR to a series of transactions that used the stop loss rule in 40(3.6) to create basis not caught by the PUC grind in 84.1, which in turn allowed…
Self-assessing GAAR?
In Quinco Financial Inc v R, 2016 TCC 190, Justice Bocock held that interest on a GAAR assessment accrues from the balance due date, just like any other assessment. His Honour, however, in obiter, also stated that a taxpayer has…