CRA is showing a continued disinterest in the GST/HST GAAR rule?

The new CRA Memorandum on the GST/HST general anti-avoidance rule is a bland and superficial paraphrase which is devoid of any insight that might have been garnered from a review of the extensive jurisprudence on the very similar income tax provision. Its perfunctory character may be consistent with a continued neglect of GAAR from the GST/HST solitude (see Murray). There have been essentially no GST GAAR cases (cf Michelin).

Neal Armstrong. Summary of GST/HST Memorandum 16-4 "Anti-avoidance Rules" under ITA s. 245(4).