Informal Request for ATI Records Previously Released

Organization: Canada Revenue Agency

Year: 2025

Month: February

Request Number: A-2024-181497

Request Summary: All records relating to the potential application of the General Anti-Avoidance Rule (GAAR) to the provisions of the Income Tax Act (ITA) relating to manipulation of Canadian-Controlled Private Corporations (CCPC) status to avoid anti-deferral rules for investment income. Related to transaction described in consultation issued by the Department of Finance on February 4, 2022.

Disposition: Disclosed in part

Number of pages: 322

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Please note To the extent possible, the institution will return the requested records in the format selected, but it may not be able to accommodate all electronic formats due to size limitations.
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