Burlington Resources Finance Company v. The Queen, 2017 TCC 144 -- summary under Subsection 107(1)

CRA disallowed, in full, under s. 247(2)(a), the deduction by the taxpayer (“Burlington”) of guarantee fees paid to its U.S. parent. Justice...

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under advisement
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Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 95 proportionality principle did not relieve of obligation to seach through scattered indexes for relevant documents 560