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Canada’s Supreme Court Denies Appeal on Partnership Tax Dispute

April 1, 2021, 6:18 PM

Canada’s high court declined Thursday to hear an application for leave to appeal from Iberville Developments Ltd., a Montreal-based real estate company.

Iberville had claimed a realized capital loss of C$122 million (U.S.$97 million) for the 2008 tax year after it transferred ownership of shopping centers in 2005 and 2007.

The Canada Revenue Agency later reassessed the transactions as a C$140,000 capital gain.

The disagreement concerned how the Income Tax Act taxes transactions involving a partnership.

Iberville had sought to overturn a Federal Court of Canada’s July 2020 ruling that backed the agency. That judgment, as well as the decision ...