What is the proper application of the General Anti Avoidance Rule (GAAR) in the Income Tax Act, R.S.C. 1985, c 1 (5th Supp) to Canada’s bilateral tax conventions — What is the correct interpretation of those conventions in the context of the GAAR — What is the proper weight to be given to the commentaries to the OECD Model Tax Convention as extrinsic aids. — granted 08/06/2020 — Supreme Advocacy acted as agent for the Respondent.

Read the lower court decision from the FCA here.