Generally, no — in a recent technical interpretation, CRA confirmed that a Canadian corporation’s real estate used in a rental operation does not qualify for the “business..
Category: Non-Resident Tax
Beneficial Ownership and Part XIII Withholding Tax: Lessons from C&W Offshore
Under Canada’s Part XIII withholding tax rules, beneficial ownership of a cross-border payment depends on who actually receives, controls, and bears the risk on that payment —..