Fiscal residence of corporations in Canada

Abstract

"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". [...]"