Michel Ranger, Rhonda Rudick, "Federal and Provincial Tax Considerations Relating to Non-Resident Investment in Canadian Real Estate", 2019 Conference Report (Canadian Tax Foundation), 32:1 – 39

Summary Under
Tax Topics - Income Tax Regulations - Regulation 805

Factual distinction between business and property income for corporation (p. 32:4)

In the case of a corporation whose sole activity is the...

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Summary Under
Tax Topics - Income Tax Act - Section 216 - Subsection 216(1)

Tax computation where s. 216(1) election (p. 32-6)

Where a section 216 election is made, income is computed as it is (in the manner set out above)...

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Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (c)

ARQ position that shares with no connection to Quebec can be taxable Quebec property (pp. 32:20-21)

[I]n certain circumstances shares of a...

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Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (a)

Quebec taxation of income from specified immovable property

[N[on-resident inter vivos trusts that own immovable property in Quebec and that earn...

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