Tax Avoidance

News & Analysis as of

Spruce Credit: Avoidance transactions and the Duke of Westminster

In Spruce Credit Union v. The Queen (2014 FCA 143) the Federal Court of Appeal upheld the lower court’s interpretation and application of the inter-corporate dividend deduction under subsection 112(1) of the Income Tax Act...more

The Gwartz Decision: The GAAR Is Not A Filler

In Brianne Gwartz v. The Queen, 2013 TCC 86, the Crown attempted to utilize the GAAR to recharacterize as dividends certain capital gains which had been realized by a family trust and allocated to the minor-aged taxpayers in...more

HM Revenue & Customs - Tax Evasion Enforcement

There has been much publicity regarding tax avoidance of late in the UK. In the age of austerity, tax avoidance by companies is scruitnised by the press and is a hot topic with the public....more

Financial Services Tax – UK Update from Dechert’s Tax Group - February 2013: Get Ready for the GAAR

Draft clauses to introduce a new general anti-abuse rule (GAAR) into the UK tax code were published as part of the Finance Bill 2013 on 11 December 2012. Some form of general anti avoidance rule was first seriously canvassed...more

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