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3 July 2012 External T.I. 2012-0443421E5 F - 84.1 and partnership -- attach -- Subsection 245(4)

3 July 2012 External T.I. 2012-0443421E5 F - 84.1 and partnership -- attach -- Subsection 245(4)

s. 245(2) has been applied to the use of a partnership to avoid s. 84.1

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