The Resource Weak-currency borrowings and the general anti-avoidance rule in Canada: from Shell Canada to Canadian Pacific

Weak-currency borrowings and the general anti-avoidance rule in Canada: from Shell Canada to Canadian Pacific

Label
Weak-currency borrowings and the general anti-avoidance rule in Canada: from Shell Canada to Canadian Pacific
Title
Weak-currency borrowings and the general anti-avoidance rule in Canada: from Shell Canada to Canadian Pacific
Creator
Subject
Language
eng
Summary
Reviews the decision of the Tax Court of Canada in Canadian Pacific and challenges its conclusion that Canada's general anti-avoidance rule (GAAR) ought not to have applied. After a brief explanation of the economics of weak-currency borrowings and associated tax advantages absent the application of anti-avoidance rules, the decision of the Supreme Court of Canada in Shell Canada, on which the Tax Court in Canadian Pacific relied, and the decision in Canadian Pacific are examined
Citation source
In: Bulletin for international fiscal documentation. - Amsterdam. - Vol. 55 (2001),
http://library.link/vocab/creatorName
Duff, D.G
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • anti-avoidance
  • case law
Label
Weak-currency borrowings and the general anti-avoidance rule in Canada: from Shell Canada to Canadian Pacific
Instantiates
Publication
Label
Weak-currency borrowings and the general anti-avoidance rule in Canada: from Shell Canada to Canadian Pacific
Publication

Library Locations

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      52.37366609999999 4.9336932
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