It is my understanding that this was very aggressive tax planning in order to try to avoid taxation in Canada. Certain assets would have been transferred to a spousal trust in Canada and then moved into a trust in Barbados. The taxpayers would then sell the assets, which I think were shares of private corporations. Under the tax treaty, there would have been no tax paid in Barbados and no tax paid to Canada. The agency identified it under the general avoidance rules, assessed, and won the case in the courts. I think it may actually still be before the courts on those particular reassessments.
On February 14th, 2007. See this statement in context.