Kenny v. The Queen, 2018 TCC 2 (Informal Procedure) -- summary under Section 118.94

foreign government assistance scuppered the “substantially all” test in s. 118.94

In 2014, the taxpayer, who was an Irish national and resident, earned $32,728.52 in employment income from working in Fort McMurray, Canada for a...

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substantially all
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Tax Topics - Treaties - Income Tax Conventions - Article 25 s. 118.94 did not violate non-discrimination-against-nationals Art. in Canada-Irish Treaty 230