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When Subsection 250(5) of the Income Tax Act Does Not Apply: Black v. The Queen
The ongoing legal battles of Lord Conrad Black continue. This time, the issues involved are of relevance to many "dual-resident" Canadians who rely on relief under Canada's various taxation treaties in order to avoid Canadian taxation on foreign-source employment and other income. Anu Nijhawan and Marshall Haughey, "When Subsection 250(5) of the Income Tax Act Does Not Apply: Black v The Queen" (2014) Taxation of Executive Compensation and Retirement, Volume 24, Number 4, 1609.