General Electric Capital Canada Inc. v. The Queen: Guarantee Fees and the Arm’s Length Standard

Type

Journal

Author

Steeves, C.J.

Country

Canada

Published Date

May 30, 2011

Issue

Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2011 (Volume 13), No. 3

DOI

https://doi.org/10.59403/2rcrf6m

Document

Go to Tax Research Platform

This article reviews the General Electric Capital Canada decisions (Tax Court and Federal Court of Appeal) and discusses the useful commentary contained in these judgments about the application of the arm’s length principle to financial services.

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General Electric Capital Canada Inc. v. The Queen: Guarantee Fees and the Arm’s Length Standard