93 C.M.TC - Q.16
Dalsin, "Dispositions of Property by Non-Residents: Tax Deferral by Ministerial Discretion", 1991 Canadian Tax Journal, p. 77.
D'Aurelio, "International Issues: A Revenue Canada Perspective", 1990 Conference Report, c. 44, under "Section 115.1 and Related Treaty Provisions"
Sifto Canada Corp. v. The Queen, 2017 TCC 37
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|Locations of other summaries||Wordcount|
|Tax Topics - Treaties - Income Tax Conventions - Article 9||agreement with the U.S. competent authority re a VDP-adjusted transfer price binds CRA even if it had not yet audited the taxpayer||569|
|Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2)||TNMN method was reasonable||205|
|Tax Topics - Income Tax Act - Section 152 - Subsection 152(1)||MAP agreement concurred in by taxpayer was binding on the Minister as it was not “indefensible”||255|