Federal Court of Appeal overturns Tax Court on GAAR and non-CCPC planning in Canada v. DAC

By Stephanie D’Amico ( March 4, 2026, 10:28 AM EST) -- On Feb. 20, the Federal Court of Appeal released its decision in Canada v. DAC Investment Holdings Inc., 2026 FCA 35 (DAC), overturning the Tax Court of Canada’s conclusion that a corporate continuance undertaken to exit the Canadian-controlled private corporation (CCPC) regime did not constitute abusive tax avoidance....