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By services, 11 December, 2018 30 August 2004 External T.I. 2003-0001351E5 - Subsection 15(1) and section 80
By services, 2 January, 2018 25 September 1998 External T.I. 98071150 - Sale of Shares of a Non-resident Company
By services, 22 December, 2017 19 July 2005 External T.I. 2004-0074241E5 - 212(13.1)(b) and ITAR 10(6)