22 March 1995 T.I. 950463 (C.T.O. "Withholding Tax for Non-Resident Commuters (HAA 8019-1)")

"Generally if a taxpayer commutes to work in Canada for more than 182 days in a year and returns to his home daily to a country outside Canada,...

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"If an individual comes to Canada and exercises his duties of employment for a Canadian company and the costs, whether directly or indirectly, are...

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