Principal Advisors

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Offices

Equilease Corporation in one of first cases to consider General Anti-Avoidance Rule

Client

Equilease Corporation

Date

April 1997
Alan Schwartz represented Equilease Corporation in one of the first cases to consider the General Anti-Avoidance Rule (GAAR). At issue was whether a sale to an unrelated corporation was a capital gain exempt under Article XIII of the Canada-US Treaty or was a taxable distribution of corporate surplus (April 1997).