9 April 1992 T.I. (Tax Window, No. 18, p. 9, ¶1856)

An allocation to a non-resident under an EPSP that relates to duties performed in Canada is required to be included in his income.

The deeming provisions of ss.144(8) and (8.2) do not result in a requirement to withhold Part XIII tax because the amounts are not considered to...

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