[Verse 1]
When taxpayers cross the criminal line
Sections two-three-eight and two-three-nine
False statements made with willful intent
Prison time and hefty fines are sent
The Crown must prove beyond doubt's shadow
That deception walked where truth should follow
[Chorus]
Tax evasion hides, avoidance bends the rules
GAAR cuts through schemes like sharpened legal tools
Two-three-eight, two-three-nine, criminal prosecution
Deans Knight changed the game, jurisprudence evolution
Mandatory disclosure, penalties that sting
Know the line before you cross that dangerous thing
[Verse 2]
General Anti-Avoidance Rule awaits
When transactions lack commercial traits
Deans Knight twenty-twenty-three Supreme Court said
Policy rationale must guide where GAAR is led
Object, spirit, purpose intertwined
Abusive tax advantages redefined
[Chorus]
Tax evasion hides, avoidance bends the rules
GAAR cuts through schemes like sharpened legal tools
Two-three-eight, two-three-nine, criminal prosecution
Deans Knight changed the game, jurisprudence evolution
Mandatory disclosure, penalties that sting
Know the line before you cross that dangerous thing
[Bridge]
Twenty-twenty-three amendments brought new fears
Reportable transactions crystal clear
Notifiable deals must see the light
Uncertain treatments filed before midnight
Aggressive planning draws the penalty sword
Transparency now the governing word
[Verse 3]
Hallmark transactions trigger the alarm
Reportable schemes that cause CRA harm
Advisor penalties for those who sell
Schemes that dance too close to legal hell
Uncertain positions need disclosure too
Or face the consequences coming due
[Chorus]
Tax evasion hides, avoidance bends the rules
GAAR cuts through schemes like sharpened legal tools
Two-three-eight, two-three-nine, criminal prosecution
Deans Knight changed the game, jurisprudence evolution
Mandatory disclosure, penalties that sting
Know the line before you cross that dangerous thing
[Outro]
Criminal fraud or planning gone astray
GAAR and disclosure block the risky way
Canadian tax law draws the boundaries tight
Between legitimate planning and criminal night