Iacobucci J.
Iacobucci J. ‑‑ We are all of the view that this appeal should be dismissed for the reasons of Marceau J.A. in the Federal Court of Appeal. We would add that in our opinion the provisions of the Canada‑Germany Tax Agreement do not apply in these circumstances to prevent the operation of s. 180.2 of the Income Tax Act. Accordingly, the appeal is dismissed with costs.
Statutes and regulations cited
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Income Tax Act