Modernizing and Strengthening the General Anti-Avoidance Rule, Department of Finance Consultation Paper, 11 August 2022

Narrowing “bona fide purpose”

• It may be appropriate to provide that a “bona fide purpose” does not include foreign (or provincial) tax...

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Extending “transaction” to include a choice

• Given the findings in Canadian Pacific and Spruce Credit (pp. 10-11), it may be appropriate to...

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Potential changes to abuse or misuse test

Potential changes to the application of the abuse or misuse test in s. 245(4) could include:

• the...

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