In Krumm v. Canada (Fed CA, 2021) the Federal Court of Appeal sets out the ITA definition of a 'tax shelter':
[14] A tax shelter as defined in subsection 237.1(1) of the Act generally describes a property that is marketed on the basis that prospective purchasers could expect a specified after-tax result if they acquire an interest in the property. The relevant part of the definition applicable to the taxation years at issue reads: "“… it can reasonably be considered, having regard to statements or representations made or proposed to be made in connection with the property, that [within a four year period] … the total of all amounts each of which is … represented to be deductible … would equal or exceed [the cost of the property, as adjusted].”"
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