For their 2005 and 2006 taxation years, the taxpayers purchased franchises for the non-exclusive right to distribute the software licences in...
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A tax shelter, for the initial (2003/2004) years assessed by the ARQ, entailed the sale by a corporation (“Prospector”) to over 200 investors...
The ARQ did not lose heart with the victory by a representative investor in a tax shelter in Drouin (where CRA unsuccessfully argued that no...