Two CRA challenges to cross-border hybrid arrangements are at the Tax Court stage

Alexandra MacLean noted that a number of files in the CRA project on cross-border hybrid mismatches have reached the notice of objection stage, two cases are at the Tax Court stage already, and some files have been resolved through audit agreements.

Neal Armstrong. Summary of Alexandra MacLean on Hybrid Mismatch Rules, 25 November 2021 CTF Panel.