The appellant appealed the Minister's reassessment denying the deduction of non-capital losses, net capital losses, and SR&ED expenditures acquired from an unrelated party.
The Minister applied the General Anti-Avoidance Rule (GAAR).
The Tax Court of Canada found that the transactions constituted an abusive tax avoidance series designed to trade tax attributes, frustrating the object, spirit, and purpose of the loss streaming rules in the Income Tax Act.
The appeals were dismissed.
