Précis: The nub of this decision is set out succinctly in the first few paragraphs:
 In 2007, CVC Capital Properties (“CVC”), a United Kingdom private equity firm, acquired Univar NV, a Netherlands public corporation. With the acquisition, CVC indirectly acquired a Canadian operating subsidiary with surplus in excess of $889,000,000. CVC carried out a series of transactions so that it could indirectly strip the surplus out of the Canadian subsidiary without paying withholding tax. The Appellant was the holding company used to accomplish the outcome in that series of transactions.
Univar Holdco Canada v. R. - TCC: Arm’s length surplus strip under 212.1(4) blocked by GAARREAD MORE »