CRA will apply GAAR to any future D&D cases

CRA, after noting that it failed to apply GAAR in D & D Livestock (which entailed "the double utilization of the same amount of safe income in order to reduce a capital gain realized on an ultimate disposition of shares"), stated that it "would not hesitate to invoke the GAAR in similar files." More generally, it will challenge planning resulting in "in an unjustified duplication of fiscal attributes."

Neal Armstrong. Summary of 10 October 2014 APFF Roundtable, Q. 20, 2014-0534671C6 F under s. 245(4).