CRA considers that non-residents servicing Canadians over the phone are not rendering services in Canada

A Canadian company which pays a non-resident call centre to service its mostly Canadian customers would not withhold under Reg. 105 on the fees of the call centre, on the basis that the call centre was not rendering services in Canada.

Presumably the same would apply to a New York investment dealer which attends Toronto meetings by telephone.

Neal Armstrong.  Summary of 9 September 2015 T.I. 2014-0563611E5 F under Reg. 105(1).