GAAR – Section 245
S.245 - GAAR - The General Anti-Avoidance Rule
The General Anti-Avoidance Rule (“GAAR”) is a catch-all provision found in section 245 of Part XVI of the Income Tax Act, RSC 1985, c 1 (5th Supp) titled “Tax Avoidance”.
In short, GAAR provides the Canada Revenue Agency (“CRA”) with the broad power to object to a...