Subsection 124(1) - Deduction from corporation tax
18 October 89 Meeting with Quebec Accountants, Q.8 (April 90 Access Letter, ¶1166)
RC acknowledges that a taxable capital gain realized by a non-resident corporation from the disposition of taxable Quebec property will not be creditable if the non-resident corporation has no permanent establishment in Canada.
Subsection 124(4) - Definitions
Taxable Income Earned in the Year in a Province
Noranda Mines Ltd. v. The Queen, 85 DTC 5001,  CTC 659 (FCA)
The words "taxable income earned in the year" in former s. 124(2)(b) referred to income for the year minus the deductions permitted by Division C for the taxation year, such as losses carried forward from prior years under section 111.
85 C.R. - Q.7
RC does not accept a provincial request to change the allocation of taxable income of the provinces until it is satisfied that the provincial position is correct.