Canadian Tax Court upholds POEM for Dutch co. in Canada, applies central management & control test

Aug 03,2018

Tax Court of Canada holds the Dutch co. (appellant) as tax resident of Canada as it was centrally managed and controlled from Canada through the Backxes (shareholders in appellant co. and immigrated to Canada), upholds capital gains taxability for disposition of a partnership interest in a dairy-farm operation located in Ontario ; Notes that in subject tax year 2009, the Backxes incorporated Dairy Farm co. in Canada and transferred their 51% interest in the Dairy-...

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