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2763478 Canada Inc. v. The Queen, 2017 TCC 98, aff'd 2018 CAF 209 -- attach -- Subsection 245(4)

2763478 Canada Inc. v. The Queen, 2017 TCC 98, aff'd 2018 CAF 209 -- attach -- Subsection 245(4)

value-shift transactions were abusive

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