Husky Oil Limited v. The Queen: Clarifying the Scope of the Amalgamation Anti-Avoidance Rule, Tax Litigation, v. XVII no. 3 (2010) p. 1054
Date:
April 20 2011
The Federal Court of Appeal’s decision in Husky Oil Limited v. The Queen sets out in clear terms the purpose of subsection 87(4) of the Income Tax Act and offers some clarity to taxpayers contemplating corporate amalgamations to which subsection 87(4) will apply. In addition, this decision provides useful guidance that may assist taxpayers in challenging any tax assessment based largely on the assumptions of fair market value by the Minister of National Revenue (the “Minister”).
Republished with permission from Federated Press.
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