Dunne v. Quebec (Deputy Minister of Revenue), 2007 DTC 5248, 2007 SCC 19, [2007] 1 SCR 853 -- summary under Subsection 92(2)

Provisions of the Taxation Act (Quebec) which subjected the taxpayer to Quebec income tax on retiring allowances received by him from a professional partnership of which he had been a member and which carried on business in Quebec were intra vires given that the partnership agreement itself established that the amounts received by him represented a share of profits of the partnership. Accordingly, the assessment was not based on a legal fiction and the deeming provisions operated to determine the portion of the taxpayer's income that could be allocated to the partnership's Quebec activities.