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Canada Case Law

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Income tax 2023 TCC 167

Husky Energy Inc. v. The King

Tax Court judgment on Part XIII withholding, treaty relief, beneficial ownership, and GAAR in a cross-border dividend structure involving Luxembourg and Barbados entities.

  • Beneficial ownership
  • Treaty shopping
  • Securities lending
  • Withholding obligations
  • Gaar application
  • Treaty interpretation
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Canada decisions are organised by court, judge, legal area and indexed issue so a practitioner can move from a proposition to a citable authority with the surrounding context intact.