I'm not experienced enough or expert enough to make a comment in the area of application of GAAR to double dipping, but in the case of the interest deductibility for third-party debt raised to fund foreign acquisitions, the GAAR and the thin cap rules apply to non-arm's-length debt.
If a company is levered up because the banks are willing to give them 99% debt—and banks of the world do not give 99% debt—basically, in the income trust situation, it's the non-arm's-length debt that enables the avoidance of tax. It's on that basis that I say GAAR and thin cap rules apply, because it's clearly non-arm's-length debt, whereas in the case of interest deductibility, it was actually seen to be a problem for the Canadian banks because they wanted the ability to provide billions of dollars to Canadian corporations so that they could take the proceeds of that to acquire foreign operations.