"The words "persons" and "taxpayers" as used in the "Income Tax
Act" include corporations (section 248(1)). As Hogg points out, "[ilt is
therefore as necessary for a corporation as it is for an individual to
determine the place of residence in order to decide whether it is liable
to Canadian tax on its world income. In the absence of any exhaustive
definition of residence in the Act, the courts have had to develop a test
of residence for corporations just as they have for individual". [...]"