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Case Name | Citation(s) | Court | Jurisdiction | Date † | Full Text | Citation Index | |
98 DTC 2021 |
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Canada | circa 2021 |
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"Prepayment and anti-avoidance measures" |
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Taxation in Australia | Australia | circa 2000 |
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"The New Business Tax System: Life after Ralph" |
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Taxation in Australia | Australia | circa 2000 |
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"Canada: GAAR Update" | [1999] Journal of International Taxation 38 | Journal of International Taxation | circa 1999 |
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"Budget Analysis" |
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Law Society's Gazette | United Kingdom | circa 1999 |
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"The Ralph Report Protecting the Income Tax Base" |
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Taxation in Australia | Australia | circa 1999 |
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"The Consultative Document on a General Anti-Avoidance Rule for Direct Taxes – A View from Business" |
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British Tax Review | United Kingdom | circa 1999 | Westlaw |
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"Supreme Court of Canada Re-affirms Use of Holding Co and Dividends as Income Splitting Technique" | (1999) 10 Journal of International Taxation 58 | Journal of International Taxation | circa 1999 |
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"GST Anti Avoidance – Division 165" | (1999) 5 Journal of Australian Taxation 295 | Journal of Australian Taxation | Australia | circa 1999 | Informit / LexisNexis |
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(1999) 2 Journal of Australian Taxation 437 | (1999) 2 Journal of Australian Taxation 437 | Journal of Australian Taxation | Australia | circa 1999 | Informit / LexisNexis |
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"The Consultative Document on a General Anti-Avoidance Rule for the United Kingdom – A View from a Practicing Lawyer" |
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British Tax Review | United Kingdom | circa 1999 | Westlaw |
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"Canadian Tax Wrap Up" | (1999) 10 Journal of International Taxation 43 | Journal of International Taxation | circa 1999 |
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"Osborne v FCT - The Lost Opportunity?" |
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Tax Specialist | circa 1999 |
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Commissioner of Inland Revenue v Yick Fung Estates Ltd |
[1998] HKCFI 582; |
Hong Kong Court of First Instance | Hong Kong | 30 Oct 1998 | HKLII |
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"The Illusive Interest Deduction" |
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Canadian Current Tax | Canada | circa 1998 |
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"General Anti-Avoidance in Action - News from Canada" |
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British Tax Review | United Kingdom | circa 1998 | Westlaw |
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"Part IVA of the income tax assessment act after spotless – a brave new world?" | (1998) 72 Australian Law Journal 303 | Australian Law Journal | Australia | circa 1998 | Legal Online |
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Wither v CIR |
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New Zealand | circa 1998 | CCH New Zealand |
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"Background to the GAAR: Ramsay and McGuickian" |
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Tax Journal | United Kingdom | circa 1998 |
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"Australia ’ s General Anti-Avoidance Rule: Part IVA has Teeth, but are Some Missing?" |
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British Tax Review | United Kingdom | circa 1998 | Westlaw |
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"PART IVA: Seriously Flawed in Principle" | (1998) 1 Journal of Australian Taxation 57 | Journal of Australian Taxation | Australia | circa 1998 | AustLII |
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KJ Cummings Ltd v CIR |
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New Zealand | circa 1998 | CCH New Zealand |
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"The Substance Over Form Doctrine Applied to Tax Avoidance Schemes" | (1998) South African Law Journal 646 | South African Law Journal | South Africa | circa 1998 | HeinOnline |
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"Part IVA: Post Spotless" | (1998) 1 Journal of Australian Taxation 3 | Journal of Australian Taxation | Australia | circa 1998 | AustLII |
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"GAAR: Empty Threat or Deal Stopper?" | (1998) 9 International Tax Review 13 | International Tax Review | United Kingdom | circa 1998 | HeinOnline |
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(1997) 31 Taxation in Australia 364 |
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Taxation in Australia | Australia | circa 1997 |
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McNichol v Canada |
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Canada | circa 1997 |
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"Interpretations of GAAR: Before and Beyond McNicol and RMM" |
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Queen's Law Journal | Canada | circa 1997 | HeinOnline / LexisNexis |
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"Anti-Avoidance Principles - New Directions for Tax and Business Resulting from the High Court Decision in Spotless" | (1997) 25 Australian Business Law Review 142 | Australian Business Law Review | Australia | circa 1997 | Legal Online |
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"Canadian Tax Court decides First Case under General Anti-Avoidance Rule" | (1997) 8 Journal of International Taxation 126 | Journal of International Taxation | circa 1997 |
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"Tax Litigation - Disclosure of Rulings" |
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Canadian Current Tax | Canada | circa 1997 |
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"Tax Avoidance with a Little Help from Downunder" |
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Canadian Tax Journal | Canada | circa 1997 |
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"Spotless: Removing the Stain of Tax Avoidance in Australia" |
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British Tax Review | United Kingdom | circa 1997 | Westlaw |
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"Canada's Anti-Avoidance Rule Applied to US Disposition of Canadian Subsidiary" | (1997) 26 Tax Management International Journal 478 | Tax Management International Journal | United States | circa 1997 |
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"First Court Decision on Canada's Statutory Business Purpose Test: McNicol v R" | (1997) 26 Tax Management International Journal 135 | Tax Management International Journal | United States | circa 1997 |
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"The Ghost of the Duke of Westminster Laid to Rest in Australia?" |
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Canadian Tax Journal | Canada | circa 1997 |
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"Through a Spotless Glass, Darkly" |
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Taxation in Australia | Australia | circa 1997 |
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"The 1996 Amendments to the General Anti-Tax Avoidance Section of the Income Tax Act" | (1997) 114 South African Law Journal 675 | South African Law Journal | South Africa | circa 1997 | HeinOnline |
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"What has the Tax Court of Canada Added to the GAAR Analysis?" |
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International Tax Review | United Kingdom | circa 1997 | HeinOnline |
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"Purposive Interpretation as a Weapon Against Tax Avoidance" |
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Canadian Current Tax | Canada | circa 1997 |
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"The Tension Between the Westminster Principle and Abusive Tax Avoidance" |
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Canadian Current Tax | Canada | circa 1997 |
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Miller v Commissioner of Inland Revenue |
[1996] NZHC 1625; |
High Court of New Zealand | New Zealand | 8 Nov 1996 | NZLII |
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I Lady Smith (Pty) Ltd v C of IR |
[1996] ZASCA 35; |
Supreme Court of Appeal of South Africa | South Africa | 28 Mar 1996 | SAFLII |
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"An Economic Approach to Taxation Avoidance" | (1996) 2 New Zealand Journal of Taxation Law and Policy 171 | New Zealand Journal of Taxation Law and Policy | New Zealand | circa 1996 |
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"First GAAR Case an Easy Win for Revenue" |
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Canadian Current Tax | Canada | circa 1995 |
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"Tax Avoidance: 1945-1995" |
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Canadian Tax Journal | Canada | circa 1995 |
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"The Future of Australia's General Anti-Avoidance Provision" | (1995) 1 New Zealand Journal of Taxation Law and Policy 225 | New Zealand Journal of Taxation Law and Policy | New Zealand | circa 1995 |
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"The Canadian General Anti-Avoidance Rule" |
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British Tax Review | United Kingdom | circa 1995 | Westlaw |
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"Is There a Need for General Anti-Avoidance Legislation in the United Kingdom?" |
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British Tax Review | United Kingdom | circa 1994 | Westlaw |
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Hadlee v Commissioner of Inland Revenue |
[1993] UKPC 8; |
Privy Council | New Zealand | 1 Mar 1993 | BAILII |
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"Preparing for NAFTA: Canadian Judicial Anti-avoidance Doctrines Part I" | (1993) 19 International Tax Journal 1 | International Tax Journal | United States | circa 1993 | HeinOnline |
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Hadlee v Commissioner of Inland Revenue |
[1991] NZCA 257; |
Court of Appeal of New Zealand | New Zealand | 31 May 1991 | NZLII |
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"Is GAAR Void for Vagueness?" |
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Canadian Tax Journal | Canada | circa 1989 |
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"Tax Law Review Committee Report on Tax Avoidance" |
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British Tax Review | United Kingdom | circa 1988 | Westlaw |
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"A Review and Analysis of the Redrafted General AntiAvoidance Rule" |
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Canadian Tax Journal | Canada | circa 1988 |
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Bigras v R |
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Canada | circa 1988 |
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"The General Anti-Avoidance Rule – Part 1" |
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Canadian Tax Journal | Canada | circa 1988 |
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"A New and More Coherent Approach to Tax Avoidance" |
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Canadian Tax Journal | Canada | circa 1988 |
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Challenge Corporation Ltd v CIR |
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New Zealand | circa 1986 | LexisNexis |
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Stubart Investments Ltd v R |
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Supreme Court of Canada | Canada | circa 1984 |
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Newton v FCT |
[1958] UKPCHCA 1; |
Privy Council | Australia | 7 Jul 1958 | AustLII |
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Inland Revenue Commissioners v Duke of Westminster |
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United Kingdom | circa 1936 | LexisNexis / Westlaw |
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Hollinger Inc v R |
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Canada | circa 1913 |
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Shell Canada in Canadian Pacific Ltd v R |
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Canada |
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99 DTC 324 |
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Canada |
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99 DTC 308 |
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Canada |
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Continental Bank Leasing Corporation v R |
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Canada |
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Duha Printers (Western) Ltd v R |
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Canada |
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Shell Canada Ltd v Canada |
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Canada |
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Hickman Motors Ltd v R |
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Canada |
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Where a |
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Canada |
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Mara Properties Ltd v R |
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Canada |
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Friesen v R |
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Canada |
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Antoska v R |
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Canada |
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