ARTICLE · 14 JANUARY 2014

CRA Rocks The Boat: Garber Et Al. v. The Queen

Dentons Canada LLP

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Readers who were tax practitioners in the mid-80s will well remember the luxury yacht tax shelters, which were sold in 1984, 1985 and 1986 and which were one of the most popular tax shelters of that period.

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"Now then, Pooh," said Christopher Robin, "where's your boat?"
"I ought to say" explained Pooh as they walked down to the shore of the island "that it isn't just an ordinary sort of boat. Sometimes it's a Boat and sometimes it's more of an Accident. It all depends".
"Depends on what?"
"On whether I am on the top of it or underneath it"
A. A. Milne, Winnie-the-Pooh

Readers who were tax practitioners in the mid-80s will well remember the luxury yacht tax shelters, which were sold in 1984, 1985 and 1986 and which were one of the most popular tax shelters of that period. Many of us had clients who invested in this tax shelter and are aware that the CRA was very upset with this tax shelter and reassessed all of the investors. Tax practitioners from that period will also remember that the promoter of the tax shelter and several of his associates were prosecuted and convicted in connection with the luxury yacht tax shelter.

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