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Corporations - entity's business is exercised from within...

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Corporations * All corporations incorporated (under the federal or provincial jurisdiction) in Canada are considered residents of Canada and are subject to tax on world income regardless where the controlling shareholders reside (in Canada or In any foreign jurisdiction) * Under Canadian common law, a company incorporated in a foreign jurisdiction may be resident in Canada if it can be established that the "central management and control" over the major policy affairs of the
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Unformatted text preview: entity's business is exercised from within Canada * This common-law test is seldom applied due to the obvious difFculties of enforcement and the negative effects it would have on international trade with respect to Canadians carrying on business abroad * Rather, it seems to be used to combat tax avoidance schemes and usually does not affect normal international business or investment structures...
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