| That is, the GAAR did not apply to disallow the effective deduction by Mr. Lipson of the interest on the bank loan and refinancing loan obtained by Mrs. Lipson to purchase the Holdco shares from him. |
| The court has advised the parties to be prepared to address the impact of Lipson at the hearing. |
| The Minister disallowed the interest expense claimed by Mr. Lipson on the basis that the GAAR applied and that the series of transactions amounted to abusive tax avoidance. |
| Consideration will likely be given to seeking advance rulings on a broader range of transactions to address the uncertainties created by certain aspects of the majority decision in Lipson. |
| We are very pleased to have Alan Lipson join our team as President of National Insurance. |
| Existing tax plans should be re-examined in light of the Lipson decision. |
