ABSTRACT
One way of targeting a known abusive tax avoidance scheme is by specific rules, known as Specific Anti-Avoidance Rules (SAARs). SAARs, however, tend to lead to overly complicated and burdensome tax rules. An alternative measure is a judicial doctrine, such as the doctrine of economic substance in the United States. Reuven S. Avi-Yonah and Amir Pichhadze outline the limitations of this doctrine and contrast it with the Canadian General Anti-Avoidance Rule (GAAR). They further identify important factors that should be used in analyzing GAARs and discuss the application of these factors should the United States lawmakers consider implementing a GAAR.
