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The Federal Court of Appeal Applies GAAR in a Partnership Loss Transfer Strategy: Canada v. 594710 British Columbia Ltd., 2018 FCA 166

Overturning the Tax Court of Canada’s (Tax Court) decision, the Federal Court of Appeal (FCA) ruled in 594710 British Columbia Ltd that GAAR is applicable in a loss utilization strategy where a new partner (Nuinsco) with a significant unused loss balance entered a partnership to facilitate an allocation of virtually all the partnership’s income, availing the former […]

The Federal Court of Appeal Applies GAAR in a Partnership Loss Transfer Strategy: Canada v. 594710 British Columbia Ltd., 2018 FCA 166 Read More »

The Federal Court of Appeal Applies GAAR in a Partnership Loss Transfer Strategy: Canada v. 594710 British Columbia Ltd., 2018 FCA 166

Overturning the Tax Court of Canada’s (Tax Court) decision, the Federal Court of Appeal (FCA) ruled in 594710 British Columbia Ltd that GAAR is applicable in a loss utilization strategy where a new partner (Nuinsco) with a significant unused loss balance entered a partnership to facilitate an allocation of virtually all the partnership’s income, availing the former

The Federal Court of Appeal Applies GAAR in a Partnership Loss Transfer Strategy: Canada v. 594710 British Columbia Ltd., 2018 FCA 166 Read More »

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