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The Supreme Court of Canada dismissed the taxpayers’ appeal in Fundy Settlement (also known as Garron or St. Michael Trust Corp.), deciding on April 12, 2012 that the relevant trusts were resident in Canada rather than Barbados for purposes of Canada’s Income Tax Act
Today, Canada's highest court denied leave to appeal in Mackay, a case in which the Federal Court of Appeal held that the general anti-avoidance rule (“GAAR”) under the Income Tax Act (Canada) applied to a structured acquisition that resulted in the transfer of losses between arm's-length parties
