In each of the following Cases the individual is a U.S. resident who is disposing of a property. Determine whether any gain on the disposition is taxable under Part I in Canada.
Case 1 In 2020, Nancy Gordon disposed of shares of a widely held Canadian public company that she acquired in 2017. Nancy never owned more than one-quarter of 1 percent of the outstanding shares of this company. The company’s assets consist entirely of real estate situated in Canada. Case 2 In 2015, Joe Nesbitt acquired a condo in Whistler that he rented to Canadian residents. He sold the condo in 2020 at a considerable gain. Joe never occupied the condo. Case 3 Assume the same facts as in Case 2, except that Joe incorporates a private corporation under British Columbia legislation solely to acquire the condo. At a later point in time, Joe sells the shares at a considerable gain. Case 4 Assume the same facts as in Case 3, except the corporation is created under Washington state legislation