IT-494 "Hire of Ships and Aircraft from Non-Residents"

Where rent for the use of a ship is paid in advance, so that the actual time spent in Canada has not yet been established, it is acceptable to base the amount withheld on reasonable estimates drawn up from proposed itineraries, and for any resulting excesses or defiencies to be made up out of subsequent rental payments to the non-resident owner of the ship.

RC will not apply the penalty provisions of s. 227(8)(a) in respect of a deficiency in tax withheld on an advance payment of rent respecting a bareboat charter for hire both inside and outside Canada, if the payer can demonstrate that he made a reasonable estimate of the proportionate use outside Canada.

Canada includes the territorial sea of Canada as defined in the Territorial Seas and Fishing Zones Act, and the overlying airspace.