
Dividend-stripping case sharpens the boundaries of legitimate tax planning
The Tax Court has affirmed the choice principle but raised fresh questions about where legitimate tax-efficient structuring ends and impermissible avoidance begins.

The Tax Court has affirmed the choice principle but raised fresh questions about where legitimate tax-efficient structuring ends and impermissible avoidance begins.

Practitioners warn that applying section 7(8) to cross-border trust distributions could create onerous and potentially perpetual tax and compliance consequences.