Administrative Policy
Income Tax Technical News No. 44, 14 April 2011
Can CRA comment on the “reasonably be expected” test where the corporation that is the recipient of the services has never performed the...
Articles
Brian Robson, "Provincial Income Allocation", Canadian Tax Highlights, Vol. 24, No. 8, August 2016, p. 3
Only applies if paymaster corp's employees spend 90% of their time on the related corp's activity (p. 3)
The central-paymaster provision in...