31 August 2005 Internal T.I. 2005-0134831I7 F - Capital Gains Exemption Strip -- attach -- Subsection 245(4)
the use of s. 40(3.6)(b) for surplus-stripping purposes would be referred to the GAAR Committee
Subsection 245(4)
Canada v. Alta Energy Luxembourg S.A.R.L., 2021 SCC 49, [2021] 3 SCR 590 -- attach -- Subsection 245(4)
Treaty shopping to avoid capital gains tax on Canadian resource assets was contemplated, and not a Treaty abuse
7 October 2021 APFF Roundtable Q. 4, 2021-0900921C6 F - Mind and management et statut de SPCC -- attach -- Subsection 245(4)
using a foreign corporation with Canadian CMC to produce a lower tax rate on investment income could be GAARable
Canada v. Deans Knight Income Corporation, 2021 FCA 160, aff'd 2023 SCC 16 -- attach -- Subsection 245(4)
avoidance of a de jure acquisition of a Lossco through acquiring “actual control” was abusive
Magren Holdings Ltd. v. The Queen, 2021 TCC 42, aff'd on other grounds 2024 FCA 202 -- attach -- Subsection 245(4)
no CDA addition where capital gains were not real
1995 Ontario Tax Conference Round Table, Q. 5 (No. 952503) -- attach -- Subsection 245(4)
Grenon v. The Queen, 2021 TCC 30, aff'd in part 2025 FCA 129 -- attach -- Subsection 245(4)
purported establishment of “alter ego” MFTs through which an RRSP could invest in operating businesses was an abuse engaging GAAR
27 May 2008 External T.I. 2008-0269441E5 F - Withdrawn Ruling Request -- attach -- Subsection 245(4)
GAAR applied to use of outside basis, created with the capital gains exemption, for an inter-sibling transfer
IC88-2 - General Anti-Avoidance Rule 21 October 1988 -- attach -- Subsection 245(4)
26 November 2020 STEP Roundtable Q. 12, 2020-0839981C6 - 21 year planning, 107(5) and TCP -- attach -- Subsection 245(4)
s. 107(2) rollout by Canadian discretionary trust to a NR-owned Canadian corporate beneficiary appears abusive
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