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TCC (summary)
Société générale valeurs mobilières inc. v. The Queen, 2016 TCC 131, aff'd 2017 FCA 3 -- summary under Article 24
The Queen, 2016 TCC 131, aff'd 2017 FCA 3-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Brazilian tax sparing provision did not permit the taxpayer to shelter Canadian-source income The Crown brought a motion under Rule 58(1) for determination of questions of law respecting the application of Art. ...