The author asks whether Agence du revenu du Québec c. Custeau, 2020 QCCA 1496, aff’g 2018 QCCQ 5692 (discussed here) reverses a trend that gave an expanded meaning to the phrase “series of transactions” in subsection 248(10) of the Income…
Series of transactions
In Agence du revenu du Québec c Custeau, 2020 QCCA 1496, the Court considered whether PUC shift and a subsequent reduction of that PUC were part of the same series of transactions such that the Quebec GAAR would apply to…
Series of transactions
It’s frustrating for clients when I tell them that about the “series of transactions” concept as it relates to related party butterflies. I tell them there’s no bright line test for what constitutes a series so that there is always…