OrbitaxTreaty between Canada and Luxembourg – Canadian Federal Court of Appeal upholds Tax Court decision on non-applicability of general anti-avoidance rule to sale of shares
|Treaty Development|Canada-Luxembourg
The Federal Court of Appeal gave its decision on 23 June 2007 in the case of Mil (Investments) S.A. v. Her Majesty the Queen. Details of the decision are summarized below.
(a) Facts. An individual, Jean-Raymond Boulle, acquired shares of Diamond Field Resources Ltd. (DFR), a Canadian public company. The shares were transferred to the Appellant, a newly incorporated…
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