Tax Interpretations has translated a technical interpretation (2017-0683511E5) in which the CRA states that using a redemption of shares to avoid s. 55(2.1)(b) is potentially GAAR-able.
I have another translation: the government needs to invoke GAAR to cooper up its (relatively) recent and detailed amendments to an already complex set of anti-avoidance rules because it refuses to accept that the regime for taxing (or maybe not taxing) inter-corporate dividends in Canada is broken and needs a radical overhaul.
