Agence du revenu du Québec v. Cristofaro, 2021 QCCA 1025

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Summaries

Summary Under

Oceanspan applied to find that a non-resident with no sources of income in Quebec could not transfer a tax credit to a Quebec taxpayer

The taxpayer, who was an Ontario resident, paid taxes in Quebec as a result of his professional firm carrying on a portion of its practice through...

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Summary Under

Oceanspan applied to preclude credit transfer from a non-taxpayer

In 2003-0026827, CRA applied Oceanspan to find that a non-resident student who has no Canadian sources of income is precluded from transferring...

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