The Resource New guidance on the application of the offshore investment fund rules : Gebro Holdings Company v. The Queen : 2016 TCC 173

New guidance on the application of the offshore investment fund rules : Gebro Holdings Company v. The Queen : 2016 TCC 173

Label
New guidance on the application of the offshore investment fund rules : Gebro Holdings Company v. The Queen : 2016 TCC 173
Title
New guidance on the application of the offshore investment fund rules : Gebro Holdings Company v. The Queen : 2016 TCC 173
Creator
Subject
Language
eng
Summary
The recent decision of the Tax Court of Canada in Gerbro Holdings Company v. The Queen is the first judgment to consider the application of the offshore investment fund rules (the OIF rules) contained in section 94.1 of the Income Tax Act to interests in arm's length investment funds based in what have traditionally been viewed as tax havens (in particular, the Cayman Islands, the Netherlands Antilles, and the British Virgin Islands). The decision, a win for the taxpayer, held that, in the taxpayer's particular circumstances, tax considerations were not "one of the main reasons" motivating the taxpayer to invest in, and hold shares of, the offshore funds issue. Therefore, the OIF rules were found not to apply to the taxpayer
Citation source
In: Canadian tax journal = Revue fiscale canadienne. - Toronto. - Vol. 64 (2016), no. 4 ; p. 825-831
http://library.link/vocab/creatorName
Irvine, C
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • investment fund
  • offshore fund
  • tax haven
  • case law
Label
New guidance on the application of the offshore investment fund rules : Gebro Holdings Company v. The Queen : 2016 TCC 173
Instantiates
Publication
Label
New guidance on the application of the offshore investment fund rules : Gebro Holdings Company v. The Queen : 2016 TCC 173
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...