Ferrel v. R., 99 D.TC 5111, [1999] 2 CTC 101 (FCA) -- summary under Tax Avoidance

After referring to the statement in Neuman (98 D.TC 6297) that "taxpayers can arrange their affairs in a particular way for the sole purpose of deliberately availing themselves of the tax reduction levies" and noting that this included the use of corporate structures for the sole purpose of avoiding tax, Linden J.A. stated (at p. 5111) that "it follows that other structures, including trusts, may also be used to save tax, as long as proper legal documentation is prepared to accomplish the purpose desired".