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In Each of the Following Cases, Determine Whether the U

Question 53

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In each of the following Cases, determine whether the U.S. resident who is disposing of property is taxable under Part I in Canada on any gain resulting from the disposition.
Case 1 - In 2015, Anne Mason acquired a condo in Canmore, Alberta that she rented to Canadian residents. She sold the condo in 2020 at a considerable gain. Anne never occupied the condo.
Case 2 - Assume the same facts as in Case 1, except that Anne incorporates a private corporation under Alberta legislation which acquires the condo. Anne sells the shares of the private company at a later point for a considerable gain.
Case 3 - Assume the same facts as in Case 2, except the corporation is created under Oregon state legislation.

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Case 1 - Anne is taxable on the gain. Th...

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