The author provides a summary of the detailed analysis undertaken by the Court in Gladwin Realty Corporation v Canada, 2020 FCA 142 to determine the object and spirit of the provisions of the Income Tax Act (Canada) at issue in a GAAR case (the CDA and negative ACB provisions).
Éric Hamelin “Determining Object, Spirit, and Purpose in a GAAR Case: Gladwin Realty” Tax for the Owner-Manager 21:1 (January 2021)
