Article 4

Cases

CGI Holding LLC v. Canada (National Revenue), 2016 FC 1086

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Tax Topics - Income Tax Act - Section 227 - Subsection 227(10.1) s. 227(10.1) application nullified as CRA not given enough time 198

Trieste v. Canada, 2012 FCA 320, aff'g 2012 DTC 1125 [at 3133], 2012 TCC 91

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St. Michael Trust Corp. v. Canada, 2010 DTC 5189 [at 7361], 2010 FCA 309, aff'd sub nom Fundy Settlement v. Canada, 2012 DTC 5063 [at 6881], 2012 SCC 14

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) accessing Treaty residence not abusive 112
Tax Topics - Income Tax Act - Section 94 - old 205

Morris v. Canada (National Revenue), 2009 FC 434

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Bujnowski v. Canada, 2006 DTC 6071, 2006 FCA 32

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Allchin v. Canada, 2004 DTC 6468, 2004 FCA 206

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Tax Topics - Income Tax Act - Section 180 - Subsection 180(3) correctness standard for isolated legal error 60
Tax Topics - Treaties technical explanations 26

Crown Forest Industries Ltd. v. Canada, 95 DTC 5389, [1995] 2 S.C.R. 802

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Words and Phrases
by reason of
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Tax Topics - Treaties 81

Placrefid Ltd. v. The Queen, 92 DTC 6480 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 6 127

See Also

GE Energy Parts Inc. v. Commissioner of Income Tax (International Taxation), ITA 621/2017, 21 December 2018 (High Court of Delhi)

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Tax Topics - Treaties - Income Tax Conventions - Article 7 portion of profits attributable to marketing estimated at 26% 112

Landbouwbedrijf Backx B.V. v. The Queen, 2018 TCC 142

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Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) the central management and control of a B.V. with a sole Dutch director was in Canada 303
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(c) no application of s. 128.1(1)(c) as central management and control had been in Canada from the time of the investment 270

Davis v. The Queen, 2018 TCC 110

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Anson v. HMRC, [2015] UKSC 44

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation profits of LLC earned directly by members 36
Tax Topics - Treaties - Income Tax Conventions - Article 24 UK LLC member had a personal (non-proprietary) entitlement to his share of LLC profits as they arose 465
Tax Topics - Treaties - Income Tax Conventions - Article 3 scheme in Treaty article for allocating income between jurisdictions amounted to a definition of "source" 76

Commissioner of Taxation v. Resource Capital Fund III LP, [2014] FCAFC 37 (Fed. Ct. of Austr.)

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Tax Topics - General Concepts - Fair Market Value - Other mining information not to be valued separately at reproduction cost 286
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property mining information not to be valued separately at reproduction cost 286
Tax Topics - Treaties - Income Tax Conventions - Article 13 mining information not to be valued separately at reproduction cost 286

Black v. The Queen, 2014 DTC 1046 [at 2882], 2014 TCC 12, briefly aff'd 2014 FCA 275

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Words and Phrases
purpose
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Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(2) amendments usually change the Act 171
Tax Topics - Statutory Interpretation - Other/Conflicting Statutes presumption against inconsistency 91
Tax Topics - Treaties - Income Tax Conventions - Article 29 Treaty residence not domestically applicable 271

Resource Capital Fund III LP v. Commissioner of Taxation, [2013] FCA 363 (Fed. Ct. of Austr.), rev'd supra.

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Other 392
Tax Topics - Treaties - Income Tax Conventions - Article 13 mine deriving value from information 392

Dysert v. The Queen, 2013 DTC 1070 [at 373], 2013 TCC 57

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TD Securities (USA) LLC v. The Queen, 2010 TCC 186

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Lingle v. The Queen, 2009 DTC 1705, 2009 TCC 435, aff'd 2010 DTC 5100 [at 6932], 2010 FCA 152

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Words and Phrases
habitual abode
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Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) 35

Minin v. The Queen, 2008 DTC 4463, 2008 TCC 429

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Garcia v. The Queen, 2007 DTC 1593, 2007 TCC 548 (Informal Procedure)

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Tax Topics - Treaties - Income Tax Conventions - Article 15 "derived" referred to geographic source 70

Salt v. The Queen, 2007 DTC 520, 2007 TCC 118

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Yoon v. The Queen, 2005 DTC 1109, 2005 TCC 366

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Allchin v. The Queen, 2005 DTC 603, 2005 TCC 476

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Gaudreau v. The Queen, 2005 DTC 66, 2004 TCC 840, aff'd 2005 DTC 5702, 2005 FCA 388

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) 76

Edwards v. The Queen, 2002 DTC 1856 (TCC)

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Wang v. The Queen, 2001 DTC 433 (TCC) (Informal Procedure)

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McFadyen v. The Queen, 2000 DTC 2473 (TCC), aff'd 2003 DTC 5015 (FCA)

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Boston v. The Queen, 98 DTC 1124 (TCC)

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Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) 129

Endres v. The Queen, 98 DTC 1101 (TCC)

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Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) 158

Hertel v. MNR, 93 DTC 721 (TCC)

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Padmore v. IRC, [1987] BTC 3 (Ch. D.), aff'd [1989] BTC 231 (C.A.)

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Administrative Policy

4 April 2019 Internal T.I. 2017-0736531I7 - Articles IV(6) and X(6) of the Canada-US Treaty

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Tax Topics - Treaties - Income Tax Conventions - Article 10 Art. IV(6) of the Canada-US Treaty works to reduce Canadian branch profits tax earned through multiple stacked LLCs 176

21 November 2017 CTF Roundtable Q. 11, 2017-0724081C6 - ULC-LLC structures & Treaty

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13 June 2017 STEP Roundtable Q. 3, 2017-0693451C6 - Dual-resident estate and Article (IV)

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26 April 2017 IFA Roundtable Q. 3, 2017-0691131C6 - U.S. LLPs and LLLPs

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 96 further extension of grandfathering relief for Florida and Delaware LLPs and LLLPs 166
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation general grandfathering of pre-April 26, 2017 LLPs and LLLPs 105
Tax Topics - Income Tax Act - Section 93.2 - Subsection 93.2(2) Florida and Delaware LLPs and LLLPs subject to s. 93.2 21

26 May 2016 IFA Roundtable Q. 9, 2016-0642131C6 - Article IV(7) and S-Corporations

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2014 Ruling 2014-0534751R3 - Deemed dividends from ULC holdco and Art IV(7)(b)

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2014 Ruling 2013-0491331R3 - Introduction of a partnership and Art.IV(7)(b)

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16 June 2014 External T.I. 2014-0516451E5 - Application of Canada-Israel Tax Convention

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12 February 2014 External T.I. 2013-0486931E5 - Distribution by ULC to a Trust to a NR beneficiary

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11 October 2013 Roundtable, 2013-0492821C6 F - Question 3 - APFF Round Table

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Tax Topics - Other Legislation/Constitution - Federal - Income Tax Conventions Interpretation Act - Section 4.3 s. 4.3 precludes application of tie-breaker rule 39

2013 Ruling 2012-0467721R3 - IV(7)(b) & PUC increase

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2013 Ruling 2012-0471921R3 - Deemed dividend on return of capital

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Tax Topics - Treaties - Income Tax Conventions - Article 29A base erosion test to be satisfied in current year 368

17 October 2012 External T.I. 2011-0428781E5 - US LLC owned by Canadian residents

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23 May 2013 IFA Round Table, Q. 10

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Tax Topics - Treaties - Income Tax Conventions - Article 5 comment on data centre interpretation below 260

25 September 2012 B.C. CTF Roundtable Q. 10, 2012-0457591C6 - B.C. CTF 2012 - Q.10 US LLC

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2012 Ruling 2012-0458361R3 - Cross-Border Financing

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2012 Ruling 2011-0430761R3 - Paid-up capital Increase

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19 April 2012 Internal T.I. 2012-043622I17 -

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16 February 2012 External T.I. 2011-0430841E5 - U.S. Grantor Trusts

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2 February 2012 External T.I. 2012-0434311E5 - Canada-U.S. Tax Convention

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2010 Ruling 2010-0364531R3 - Deemed dividends derived by US Residents

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2010 Ruling 2010-0361591R3 - Article IV(7)(b) Restructuring

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2010 Ruling 2010-0353101R3 - Article IV(7)(b) Restructuring

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26 October 2010 External T.I. 2009-0339951E5 - Canadian Branch Tax

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19 May 2010 IFA Roundtable, 2010-0366521C6 - Canada-United States Tax Convention

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21 December 2009 External T.I. 2009-0330491E5 - Article XXI Exemption

13 November 2009 Internal T.I. 2009-0318491I7 - Article IV(6)/IV(7) 'Same Treatment'

1 June 2009 External T.I. 2009-0319481E5 - Dividends Paid to S Corporation

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19 May 2009 External T.I. 2007-0263441E5 - Tax Treaties

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Income Tax Technical News, No. 35, 26 February 2007, "Treaty Residence - Residence of Convenience"

2006 Ruling 2004-0106101R3 - Class of German Arrangement & Treaty Benefits

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) German investment fund 52

IC75-6R2 "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada"

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6 August 2004 Miscellaneous 2004-0066621E5 - Irish Investment Undertakings

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3 August 2004 External T.I. 2003-005125 -

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29 March 2004 External T.I. 2004-005483 -

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24 March 2004 External T.I. 2003-003278 -

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2003 Ruling 2003-004406 -

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2 September 1999 TI 981635

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9 October 2009 Roundtable, 2009-0327031C6 F - REER et CR - art. IV(7)(b) Conv. Canada - É.-U.

12 March 1998 T.I. 980521

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10 November 1997 T.I. 972844 [check-the-box corp a Treaty resident]

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15 August 1997 T.I. 971126

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17 February 1997 T.I. 961753

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8 March 1996 T.I. 960067

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22 August 1995 T.I. 952040 (C.T.O. "Treaty ('Residence') Status of a 'S' Corporation"

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3 April 1995 T.I. 941645 (C.T.O. "S. Corps - LLC's Res of a Contracting State (HAA 4093 U5-100-4)

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25 October 1994 T.I. 941750 (C.T.O. "Limited Liability Company (HAA 4093-U5-100-4)")

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27 June 1994 T.I. 940600 (C.T.O. "Corporate Status of a Delaware LLC (4093-U5-100-4)")

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22 March 1994 Memorandum 940204 (C.T.O. "Centre of Vital Interests - Employee (4093 - U5 - 100 - 4)")

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93 C.M.TC - Q. 4

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17 May 1993 T.I. (Tax Window, No. 31, p. 4, ¶2510)

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8 August 1991 T.I. (Tax Window, No. 7, p. 23, ¶1389)

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14 December 1990 T.I. (Tax Window, Prelim. No. 2, p. 4, ¶1047)

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Tax Topics - Income Tax Act - Section 250 - Subsection 250(4) 66

Articles

Julie Colden, Éric Lévesque, "An In-Depth Look at the Hybrid Rules in the Fifth Protocol", 2017 Annual CTF Conference

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Brian Kearl, Carl Deeprose, "Leaving Canada's New High Tax Rate Regime: Considerations, Tips and Traps", 2016 Conference Report (Canadian Tax Foundation),32:1-24

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Kevyn Nightingale, Amir Pourzakikhani, "A Federal Permanent Establishment, But Not a Provincial One", Tax Topics, Wolters Kluwer, November 3, 2016, No. 2330, p. 1

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Tax Topics - Income Tax Act - Section 120 - Subsection 120(1) 379

Corrado Cardarelli, Peter Keenan, "Planning Around the Anti-Hybrid Rules in the Canada-US Tax Treaty", 2013 Conference Report (Canadian Tax Foundation), pp.16:1-27

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Jack Bernstein, "Canada-US Tax Traps for LLCs", Canadian Tax Highlights, Volume 22, Number 2, February 2014, p. 11

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Carl Irvine, Todd Miller, "Canadian Branch Profits Tax - Challenging the Denial of Treaty-Benefits for US LLCs", Newsletter - TerraLex Connections, 26 December 2013

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Edward Tanenbaum, "Where's Your Center of Vital Interests?: Treaty Tie-Breakers", Tax Management International Journal, Vol. 42, No. 5, May 10, 2013, p. 293

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Jack Bernstein, "Fiscally Transparent Entities and the Canada-US Treaty", Canadian Tax Highlights, Vol. 20, No. 1, January 2012

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Brian Cleave, "The Treaty Residence of Trusts in the United Kingdom and Canada: Some Thoughts on the Smallwood and Garron (or St Michael Corp) Cases", British Tax Review, 2011, No. 6. p. 705.

Kristen A. Parillo, "Canada Will Litigate U.S. LLC Questions under Fifth Protocol", Tax Notes Internationals, 4 October 2010, p. 7.

Richard Lewin, "Oh What a Tangled Web ..", International Tax, August 2010, No. 53, p. 10.

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Brad Gordica, Sara McCracken, "Canada-US Protocol: Top Five Issues fro Cross-Border Businesses", 2009 BC Conference Report

Kevin Duxbury, "Canadian-Owned US LLCs More Costly After the Fifth Protocol", Tax for the Owner-Manager, Vol. 9, No. 4, October 2009, p. 8.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 91 - Subsection 91(1) 0

Paul K. Tanaki, amp; Sarah Davidson Ladly:, "Payments by Hybrid Entities under the Revised Canada-United States Income Tax Convention", Corporate Finance, Vol. XV, No. 4, 2009 p. 1710.

Heather O'Hagan, "Canada-U.S. Tax Treaty Protocol - United States Kicks Off Ratification Process", CCH International Tax, No. 41, p. 1, August 2008

Peter A. Glicklich, Abraham Leitner, "New Canada-US Protocol Contains Certain Hybrid Entity Surprises", Selected US Tax Developments, 2007 Canadian Tax Journal, NO. 4

Richard Lewin, "A Change in Protocol: The Fifth Protocol to the Canada-U.S. Income Tax Convention", International Tax, CCH, October 2007, No. 36.

John Avery Jones, "Place of Effective Management as a Residence Tie-Breaker", International Bureau of Fiscal Documentation Bulletin, January 2005, p. 20.

R. Ian Crosbie, "Recent Development affecting Residence under Canada's Income Tax Conventions", Corporate Finance, Vol. VII, No. 2, 1999, p. 606.

D. Ward, "A Resident of a Contracting State for Tax Treaty Purposes: A Case Comment on Crown Forest Industries", 1996 Canadian Tax Journal, Vol. 44, No. 2, p. 408.

Steiss, "Issues Relating to Tax Freeze", 1993 Conference Report, c. 45

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Bissell, "Canada Interprets Tax Treaty Narrowly or U.S. Citizens Here Temporarily", Taxation of Executive Compensation and Retirement, December/January 1992, p. 531.

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