Michael Shields, "Taxation of International Shipping Companies in Canada", International Tax (Wolters Kluwer CCH), No. 88, June 2016, p. 1

Summary Under
Tax Topics - Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(c)

General non-imposition is substantially similar relief (p.2)

The country in which the foreign company is resident must provide "substantially...

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Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - International Shipping

Great Lakes exclusion (p. 3)

Transportation of goods or passengers on the Great Lakes or St. Lawrence River may not qualify as international...

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Summary Under
Tax Topics - Income Tax Act - Section 250 - Subsection 250(6)

Assimilation of connected income (p. 4)

[G]ross revenue from international shipping can only be earned from activities associated with vessels...

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