The Supreme Court of Canada will be hearing Copthorne Holdings Ltd. v. Her Majesty the Queen this coming Friday, January 21 at 9:30 a.m. The appeal is concerned with interpreting various elements of the "general anti-avoidance rule" ("GAAR") of section 245 of the Income Tax Act.
To seize the moment presented by the Copthorne Holdings appeal, the Tax Law Society at the Faculty of Law has arranged for an expert panel discussion of the issues raised by the appeal and the implications of the case for the GAAR more generally. The panel discussion will be held on Thursday, January 27 at 6:00 p.m. in the Bennett Lecture Hall at the University of Toronto Faculty of Law, which is located at 78 Queen's Park.
I will introduce the panel and provide some introductory background about the transactions and the judgment at the Federal Court of Appeal giving rise to the appeal to the Supreme Court of Canada. Following this backgrounder, the discussion will be turned over to the panel members, each of whom will be given 10 minutes to speak, after which there will be an opportunity for questions from the floor. The distinguished panelists include:
- Wayne Adams, Canada Revenue Agency
- Donald Bowman, Fraser Milner Casgrain, formerly Chief Justice of the Tax Court of Canada
- Vern Krishna, Borden Ladner Gervais, Professor of Common Law at the University of Ottawa
- Deen Olsen, Department of Justice
- Cliff Rand, Stikeman Elliott
After the conclusion of the panel at 8 p.m., there will be a reception in the Rowell Room. There is no charge to attend the event. If you are interested in attending, simply RSVP to events@taxwiki.ca.