The 2023 Canadian Federal Budget, released March 28, 2023 (Budget 2023), proposes significant amendments to expand the application of Canada's general anti-avoidance rule (GAAR). These proposals come after the federal...more
On November 26, 2021, the Supreme Court of Canada (the SCC) released its highly anticipated decision in Canada v Alta Energy Luxembourg SARL, 2021 SCC 49 [Alta Energy Lux], that addressed treaty-based holding structures and...more