The Resource Canadian appeals court upholds Loblaw's offshore bank structure

Canadian appeals court upholds Loblaw's offshore bank structure

Label
Canadian appeals court upholds Loblaw's offshore bank structure
Title
Canadian appeals court upholds Loblaw's offshore bank structure
Creator
Subject
Language
eng
Summary
In this article, the authors discuss the Canadian Federal Court of Appeal's judgment in Loblaw, which found that the taxpayer's offshore bank structure met the technical requirements for the foreign bank exemption from Canada's foreign accrual property income regime, specifically an exemption from the investment business category of such income. The court, however, was not asked to rule on whether the general anti-avoidance rule applied
Citation source
In: Tax notes international. - Falls Church. - Vol. 99 (2020), no. 4 ; p. 505-512
http://library.link/vocab/creatorName
  • Boidman, N
  • Kandev, M.N
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • case law
  • offshore bank
  • exemption
  • foreign accrual property income
  • anti-avoidance
  • GAAR
Label
Canadian appeals court upholds Loblaw's offshore bank structure
Instantiates
Publication
Label
Canadian appeals court upholds Loblaw's offshore bank structure
Publication

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