BU357 Lecture Notes - Lecture 7: Tax Treaty
Document Summary
Deeming rule to establish corporate residence not used too often. No concept of part time as corp tax year starts when it begins operation and ends when it ends operation. Corporations started in canada after april,1965 deemed canadian. A corp that"s not incorporated in canada can still be resident if centrally operates here (meaning even if operations aren"t taking place in canada but if board director discusses business here- then theyre resident) Notice: if corp deemed resident of canada at any point of the year its taxed on world wide income for the full year (no part time corps) A non resident corporation is taxed on its canadian source of income (which really means carrying of business) for the year. Carrying on business doesn"t mean in corporation case that they have to continually carry business it could be a single transaction However the provision of tax treaty can elimimate tax burden always.
