Canadian Tax Court : Rejects GAAR invocation, allows capital-gains exemption under Canada- Luxembourg treaty

Sep 27,2018

Tax Court of Canada allows capital gains exemption to appellant (a resident of Luxembourg) under Article 13(5) of the Canada-Luxembourg DTAA in respect of sale of shares of its wholly-owned Canadian subsidiary (‘Alta Canada’ engaged in shale oil business), rules that GAAR does not apply to preclude the appellant from claiming Treaty benefit; Noting that the shares derived their value principally from Alta Canada’s right to explore, drill and extract hydrocar...


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