17 May 2022 IFA Roundtable Q. 3, 2022-0926191C6 - Meaning of "goods" under 95(3)(b) -- summary under Paragraph 95(2)(b)

CRA found that the s. 95(3)(b) exclusion was unavailable where the foreign subsidiary was providing marketing services to Canco respecting the sale of Canadian residential condominiums by Canco in the course of its Canadian business, given its conclusions that real estate inventory did not qualify as “goods.”