Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251 -- summary under Subsection 245(4)

limited scope of PUC provisions reflected a policy choice

The taxpayer ("Products"), which was a corporation resident in the U.S., transferred the shares of its subsidiary ("CAHL"), which was non-resident...

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