11 October 2013 Roundtable, 2013-0492821C6 F - Question 3 - APFF Round Table -- summary under Section 4.3

After noting the introduction of s. 4.3, CRA stated:

[T]he effect of this new provision is to make it impossible to break the tie [under the Canada-U.S. Treaty tie-breaker rule] because it deems such equality to be non-existent.