Federal Court of Appeal

Canada v. Quebecor Inc., 2025 FCA 207 In Canada v. Quebecor Inc., 2025 FCA 207, the Federal Court of Appeal (“Court”) rejected the Appellant’s argument that the general anti-avoidance rule (“GAAR”) applied to a series of transactions designed to utilize capital losses within a related corporate group.  The decision...

Canada v. Loewen (F.C.A.), 2004 FCA 146, 4 FCR 3 Can the Canada Revenue Agency (“CRA”), after the expiry of the reassessment period, defend an assessment by relying on a new legal argument or additional facts that were not part of the CRA’s original assumptions, without effectively making a new...