A December ruling by the Tax Court of Canada in Birchcliff Energy Ltd. v. The Queen, 2012-1087(IT)G, sets an important precedent that compels Canadian tax authorities to provide greater disclosure in the pleadings they file when litigating a case under the general antiavoidance rule in section 245 of the Income Tax Act. (...)
Reprinted from Tax Notes Int’l, January 21, 2013

type Tax Court Compels Disclosure in GAAR Case (en anglais)