The Federal Court of Appeal has released its reasons for dismissing the appeal of the taxpayer in Antle. See Antle v. The Queen, 2010 FCA 280.
The reasons are also now available online in St. Michael Trust Corp. v. The Queen, 2010 FCA 309, aff’g Garron Family Trust v. The Queen, 2009 TCC 450, in which the Federal Court of Appeal also dismissed the taxpayer’s appeal.
The CRA and the Department of Justice are having a good fall when it comes to attacking arrangements involving offshore trusts.
