On December 6, the Supreme Court of Canada will review whether Google is carrying on business in Canada

In Equustec v. Google, the B.C. Court of Appeal found that Google was carrying on business in B.C. even though it did not have servers, offices, or resident employees there. Although this finding related to whether the B.C. courts had the jurisdiction to entertain a suit against Google rather than to a taxation issue, the decision of the Supreme Court of Canada in this case (which will be heard by it on December 6) will interest Canadian tax advisors and CRA.

Neal Armstrong. Summary of Susan McKilligan, "Carrying Business in Canada," International Tax, CCH Wolters Kluwer, No. 90, October 2016, p. 13 under s. 2(3)(b).