In this week's video we are reminded that the outcome of tax litigation can be highly uncertain. In a case on general anti-abuse rules, the taxpayer first won, then lost and finally lost again before the Canadian Supreme Court, in spite of that court (surprisingly) refusing to apply the GAAR in the Alta Energy case not that long ago. The transaction at issue, loss renewal and anti-abuse rules around it, is familiar territory in many countries' tax systems.
Want to learn more about International corporate income tax or Transfer pricing? See [ Ссылка ] and our courses at [ Ссылка ]. For more detail on our international tax course see [ Ссылка ], for transfer pricing see [ Ссылка ]
Original decision: [ Ссылка ]
