Question: Ada Taylor, a U . S . citizen and resident, owns all shares of a U . S . - based private company incorporated in

Ada Taylor, a U

.

.

citizen and resident, owns all shares of a U

.

. -

based private company incorporated in the U

.

.

This company's sole activity is buying and operating vacation rental properties in Canada. Ada sells all her shares this year to support her lifestyle, realizing a gain of $

250, 000 .

Indicate whether the non

-

resident would be subject to Part I Canadian income tax.

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