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 ...