Steve Suarez, Maire-Eve Gosselin, "Canada's Section 116 System for Nonresident Vendors of Taxable Canadian Property", Tax Notes International,9 April 2012, p. 175

Detailed discussion of application procedure and considerations.

Detailed discussion of limitations on the defence.

Includes discussion of change in CRA policy (net to gross asset value) re determination of whether shares derive their value primarily from real...

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