Univar Holdco Canada ULC v. Canada, 2017 FCA 207
| Jurisdiction | Federal Jurisdiction (Canada) |
| Court | Court of Appeal (Canada) |
| Citation | 2017 FCA 207 |
| Date | 13 October 2017 |
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12 practice notes
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Fifty Years of Taxation at the Federal Court of Appeal and the Federal Court
...amendments clariied the law. However, in Triad Gestco Ltd v Canada , 2012 FCA 258 at para 56 and in Univar Holdco Canada ULC v Canada , 2017 FCA 207 at paras 27–28 [ Univar ], the prior amendments relected a change in iscal policy. 163 Oxford Properties Group , above note 158 at para 46. ......
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Gladwin Realty Corporation v. Canada, 2020 FCA 142
...in order to support a finding of abuse, a proposition that runs against the decision of this Court in Univar Holdco Canada ULC v. Canada, 2017 FCA 207, [2019] 2 F.C.R. 569 [Univar] (Memorandum of the Appellant, para. 128 citing Univar at para. 29). POSITION OF THE [38] The Crown begins by c......
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3295940 Canada Inc. v. The Queen, 2022 TCC 68
...based on the decision of Mr. Justice Webb of the Federal Court of Appeal in Univar Holdco Canada ULC v. The Queen, 2016 TCC 159 , 2017 FCA 207 [Univar]. [61] According to that case, the alternative transactions are a relevant factor in deciding whether there was abuse or misuse in applying......
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Univar Holdco Canada Ulc V. Canada - The Relevance Of Alternative Transactions, Subsequent Amendments And Finance Commentary To The Gaar Analysis
...On October 13, 2017, the Federal Court of Appeal released its decision in Univar Holdco Canada ULC v. Canada, 2017 FCA 207. The Federal Court of Appeal overturned the decision of the Tax Court of Canada, 2016 TCC 159 , and held that GAAR did not apply to the transactions at In 2007, CVC Ca......
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4 cases
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Gladwin Realty Corporation v. Canada, 2020 FCA 142
...in order to support a finding of abuse, a proposition that runs against the decision of this Court in Univar Holdco Canada ULC v. Canada, 2017 FCA 207, [2019] 2 F.C.R. 569 [Univar] (Memorandum of the Appellant, para. 128 citing Univar at para. 29). POSITION OF THE [38] The Crown begins by c......
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3295940 Canada Inc. v. The Queen, 2022 TCC 68
...based on the decision of Mr. Justice Webb of the Federal Court of Appeal in Univar Holdco Canada ULC v. The Queen, 2016 TCC 159 , 2017 FCA 207 [Univar]. [61] According to that case, the alternative transactions are a relevant factor in deciding whether there was abuse or misuse in applying......
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Univar Holdco Canada ULC v. The Queen, 2020 TCC 15
...LLP Toronto, Ontario For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada [1] 2016 TCC 159 . [2] 2017 FCA 207. [3] No reason was given for providing the Court with an estimate in respect of this motion. Almost all, if not all, of counsels’ work in respect......
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Univar Holdco Canada ULC c. Canada,
...d’évitement devait faire partie d’une série d’opérations grâce à laquelle A-245-162017 FCA 207Univar Holdco Canada ULC (Appellant)v.Her Majesty the Queen (Respondent)Indexed as: Univar Holdco Canada ULC ......
7 firm's commentaries
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Univar Holdco Canada Ulc V. Canada - The Relevance Of Alternative Transactions, Subsequent Amendments And Finance Commentary To The Gaar Analysis
...On October 13, 2017, the Federal Court of Appeal released its decision in Univar Holdco Canada ULC v. Canada, 2017 FCA 207. The Federal Court of Appeal overturned the decision of the Tax Court of Canada, 2016 TCC 159 , and held that GAAR did not apply to the transactions at In 2007, CVC Ca......
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The Stikeman Elliott Federal Budget Commentary 2018
...ratio and the rule which generally allows contributed surplus to be converted into PUC (without any Canadian tax consequences). 7 2017 FCA 207. 8 2018 FCA The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your ......
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Not All Alternative Transactions Are Relevant For The Purposes Of The GAAR Abuse Analysis
...an alternative arrangement. See Canada Trustco Mortgage Co. v. Canada, 2005 SCC 54, para. 20. 7. Univar Holdco Canada ULC v. The Queen, 2017 FCA 207 ("Univar"), which overturned Univar Holdco Canada ULC v. R., 2016 TCC 159 ("Univar TCC"). See also more recently Fiducie Financière Satoma v. ......
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Federal Court Of Appeal's Univar Decision Provides Guidance On How To Apply The GAAR
...104-106. [3] Ibid at para 96. [4] Ibid at para 98. [5] Copthorne Holdings Ltd. v. Canada, 2011 SCC 63, at para 123. [6] FCA decision (2017 FCA 207) at para [7] Ibid at para 31. [8] Ibid at paras 24-29. [9] Ibid at para 27. [10] Ibid at para 28. [11] Ibid at para 29. [12] Ibid at para 23. Th......
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1 books & journal articles
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Fifty Years of Taxation at the Federal Court of Appeal and the Federal Court
...amendments clariied the law. However, in Triad Gestco Ltd v Canada , 2012 FCA 258 at para 56 and in Univar Holdco Canada ULC v Canada , 2017 FCA 207 at paras 27–28 [ Univar ], the prior amendments relected a change in iscal policy. 163 Oxford Properties Group , above note 158 at para 46. ......