20 February 2003 External T.I. 2002-014360

In response to a query as to whether U.S. income tax paid in excess of the proportionate Canadian income tax rate on U.S. non-investment income...

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A s. 20(12) deduction may not be taken by a U.S. citizen resident in Canada on the withholding from U.S. source property income that is in excess...

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