In 2014-0534671C6, the CRA was asked about its position on D&D Livestock Ltd. v. The Queen 2013 TCC 318. The CRA indicated that it would not hesitate to invoke the GAAR in similar cases involving duplication of tax attributes.
" The articles are of a good quality. I often print out articles or otherwise note them for bringing to the attention of my colleagues. I find Lexology a helpful and enjoyable update on current issues and would like to continue reading it."