Subsection 245(4)

no abuse in using 88(1)(d) bump to avoid s. 100 after 3-year s. 69(11) period

basis averaging scheme to transfer half of a capital gain to the taxpayer’s wife was an abuse of the attribution rules

use of corporate asset to create PUC was abuse of s. 84(1)

exception to an anti-avoidance provision should not be interpreted to undercut that anti-avoidance

objectionable for a s. 55(3)(a) spin-off to result in an increase in the aggregate outside basis

contrary to GAAR to use basis stepped up under CGD to create a capital loss permitting surplus extraction

abuse of inter-provincial income allocation formula “designed to prevent both the over-taxation and the under-taxation of income"

deliberate triggering of s. 55(2) gain does not violate GAAR

GAAR did not apply where a taxpayer deliberately triggered the application of s. 55(2)

Descarries not consistent with use of ACB on a previous capital gains crystallizatin to create a capital loss for use on a sale