On November 26, 2021, the Supreme Court of Canada (“SCC”) rendered its judgment in Canada v. Alta Energy Luxembourg S.A.R.L., 2021 SCC 49. In a 6-to-3 majority decision, the SCC upheld the decision of the Federal Court of Appeal (“FCA”), finding that the general anti-avoidance rule (the “GAAR”) did not apply to an alleged “treaty shopping” arrangement undertaken by the taxpayer.