His Majesty the King v. L.F. Management and Investment S.à.r.l.
His Majesty the King
L.F. Management and Investment S.À.R.L.
Law Firm / Organization
Aird & Berlis LLP

- Parties: The appellant was His Majesty the King. The respondent was L.F. Management and Investment S.À.R.L.

- Subject Matter: This appeal sought to set aside a Tax Court of Canada judgment, which allowed with costs the respondent’s appeal of a notice of assessment dated Aug. 1, 2016 and made under the Income Tax Act, 1985. The appeal alleged that the Tax Court, in considering whether the general anti-avoidance rule in s. 245 of the Income Tax Act was applicable, erred in law in its conclusions relating to the object, spirit, and purpose of article X of the Canada–Barbados Tax Convention, article 10 of the Canada–Luxembourg Tax Convention, s. 10(6) of the Income Tax Application Rules, and the relevant provisions of the Income Tax Act, including ss. 212(2), 215(1), and 215(6). This case is ongoing.

- Date: The hearing was set on Dec. 3, 2024.

- Venue: This was a federal case before the Federal Court of Appeal.

- Amount: No financial award was specified.

Federal Court of Appeal
A-11-24
Taxation
$ 0
11 January 2024