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Canadian Court Revisits CFC Treaty Provisions
Author(s): Peters, Matthew
Date:  February 4 2008
The Canadian Federal Court of Appeal, in Her Majesty the Queen v. CanWest Media Works Inc. (2008 FCA 5), recently weighed the paramountcy of two potentially competing treaty provisions as they relate to the taxation of foreign accrual property income under Canada’s controlled foreign affiliate regime.

As originally published in Tax Notes International, v.49, no.5, February 4, 2008, p.391

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