The taxpayer, which was a Panamanian company, owned a commercial rental building in Montréal which a real estate management company ("Edgecombe") spent approximately one day a month managing in return for a fee equal to 3% of gross rentals. The taxpayer was found to have an "establishment" in Québec because it was carrying on business at the building through its agent.
Topics and taglines
Tagline
rental building was PE
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
339923
Extra import data
{
"field_legacy_header": "<strong><em>Ivy Real Estate Corp. S.A. v. Deputy Minister of Revenue of Québec</em></strong>, [1989] 2 CTC 39 (Que. C.A.)",
"field_override_history": false,
"field_sid": "",
"field_topic_category": "seealso"
}
"field_legacy_header": "<strong><em>Ivy Real Estate Corp. S.A. v. Deputy Minister of Revenue of Québec</em></strong>, [1989] 2 CTC 39 (Que. C.A.)",
"field_override_history": false,
"field_sid": "",
"field_topic_category": "seealso"
}