The appellants engaged in a series of transactions to extract corporate surplus tax-free using their lifetime capital gains exemptions.
The Minister reassessed them under the general anti-avoidance rule (GAAR), adding dividend income to their 2013 and 2014 taxation years.
The Tax Court of Canada dismissed the appeals, finding that the transactions frustrated the object, spirit, and purpose of section 84.1 and subsection 89(1) of the Income Tax Act, constituting abusive tax avoidance.
