CRA considers that the new international shipping rules have not significantly curtailed the exemption

CRA considers that the amendments (for taxation years beginning after July 12, 2013) to the exemption in s. 81(1)(c) for international shipping income did not effect any substantial narrowing in its scope. CRA still considers that the non-resident taxpayer’s income can be exempted, even where it is not responsible for the crew, where it has “commercial management” of the ship, i.e., “the ship owner is operating the ship under the Taxpayer’s direction.” In addition, the new “international shipping” definition, which “introduced what may be considered to be a new requirement that the ships must be ‘owned or leased’ by the relevant taxpayer,” can be satisfied by the taxpayer being the charterer under a time charter (provided it has commercial management of the ship).

Neal Armstrong. Summary of 24 December 2015 Memo 2014-0560831I7 under s. 81(1)(c).