Cynthia Edwards is a U$.$S$.$ citizen and a resident of that country. She is a minority shareholder of a Canadian controlled private corporation. This corporation's only activity is buying and operating rental properties in major Canadian cities. Because of her concern about the inflated prices in both Toronto and Vancouver, she sells her shares in the company during the current year. The sale results in a total gain of $$785,000.$ Indicate whether the non$-$resident would be subject to Part I Canadian income tax.