17 May 2023 IFA Finance Update

First 2 paras. are restatements from original GAAR materials

• The first two paragraphs in s. 245(0.1) were restatements of those made...

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Change to “one of the main purposes” test modernized the test

• There were suggestions in obiter dicta that, if there is a transaction that...

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Object was to introduce an economic substance component without upending GAAR

• It was part of the elected government’s election platform and...

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