Allan Lanthier has written about how C-208 provides opportunities for abusive surplus stripping that tax professionals have only dreamed about. He has updated his post, however, to point out that the Federal Court of Appeal’s recent decision in R v Deans Knight Income Corporation, 2021 FCA 160, and specifically its use of the “actual control” concept in the GAAR context, could be an important tool for the CRA if it decides to attack C-208 surplus strips.
