Section 115.1

Administrative Policy

93 C.M.TC - Q.16

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90 C.P.T.J. - Q.30

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Articles

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"

Subsection 115.1(1)

See Also

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