[Verse 1] When judges read the Income Tax Act today They follow rules that guide them on their way First comes textual, what the words declare Then contextual, how they fit with care Purposive follows, what's the true intent Canada Trustco made the method bent [Chorus] Three approaches working hand in hand Textual, contextual, purposive stand Read the words then see how they relate Find the purpose, don't interpretate Tax Court starts it, Federal Appeal Supreme Court ends it, that's the real deal [Verse 2] Section two-four-five is GAAR's domain General Anti-Avoidance stops the game When taxpayers use arrangements that abuse The Act's purpose, GAAR will cut them loose Artificial transactions, tax benefits sought If it lacks substance, your plan comes to naught [Chorus] Three approaches working hand in hand Textual, contextual, purposive stand Read the words then see how they relate Find the purpose, don't interpretate Tax Court starts it, Federal Appeal Supreme Court ends it, that's the real deal [Bridge] Form versus substance, which one will prevail Look past the structure to the true detail Tax Court of Canada hears the first round Federal Court of Appeal, second ground Supreme Court of Canada gets the final say Three levels guide us through the legal way [Verse 3] Don't just follow what the form displays Look to substance in these modern days Courts will pierce through artificial schemes To find the truth behind financial dreams Integration guides interpretation's art Economic substance plays the vital part [Chorus] Three approaches working hand in hand Textual, contextual, purposive stand Read the words then see how they relate Find the purpose, don't interpretate Tax Court starts it, Federal Appeal Supreme Court ends it, that's the real deal [Outro] Remember Trustco's wisdom, GAAR's might Form and substance in the legal light Three courts climbing justice's long stair Canadian tax interpretation with care
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