GST/HST Memorandum 16-4 "Anti-avoidance Rules" 20 February 2015

General paraphrase.

3. ...Transactions that rely upon the strict wording of a provision in the Act to gain a tax benefit where none was intended and, therefore,...

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No self-application of GAAR

12. …[T]he determination of the tax consequences to any person, resulting from the application of section 274, will...

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3. ...Transactions that rely upon the strict wording of a provision in the Act to gain a tax benefit where none was intended and, therefore,...

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12. …[T]he determination of the tax consequences to any person, resulting from the application of [ETA] section 274, will only be made through a...

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