Document Type

Article

Publication Date

2025

Keywords

GAAR, economic substance, tax certainty

Abstract

The Canadian GAAR is an anti-abuse rule that denies the tax benefit resulted from abusive avoidance transactions. This paper examines the history, technical design, policy objectives and judicial interpretation of the GAAR. It explains the role of the new preamble and economic substance in applying the GAAR.

Comments

[This is draft chapter 15 of Principles of Canadian Income Tax Law (11th ed.) and posted with the permission of the publisher]

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