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Magren Holdings Ltd. v. The Queen, 2021 TCC 42, aff'd on other grounds 2024 FCA 202 -- attach -- Subsection 245(4)

Magren Holdings Ltd. v. The Queen, 2021 TCC 42, aff'd on other grounds 2024 FCA 202 -- attach -- Subsection 245(4)

no CDA addition where capital gains were not real

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