After noting, with respect to s. 212(13.3) that "the payor's reasonable belief, or a presumption based on the payee's address, will suffice to relieve the payor from possible liability", Finance indicated that "a similar test could be applied for purposes of an exemption from the withholding requirements of Regulation 105." The letter previously noted that "although there is no rule deeming the bank to be resident in Canada, many of the considerations that led to such a rule in the context of Part XIII tax are relevant here as well: the bank's business is carried on in Canada, and a person making a payment to the bank cannot always be presumed to know the details of the bank's situation."
