A U.S. corporation, Tellco Inc., employs three sales employees who live and work in Canada. The sales

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A U.S. corporation, Tellco Inc., employs three sales employees who live and work in Canada. The sales employees work from home offices. Tellco Inc. does not have an office or other facility in Canada. The employees are paid a monthly salary and quarterly commissions based on sales volume. The employees solicit sales from Canadian customers. The customers order products directly from the U.S. company online or by phone. Goods are shipped directly from the U.S. warehouse to Canadian customers.


REQUIRED

(1) Is Tellco Inc. carrying on business in Canada?
(2) Does Tellco Inc. have a permanent establishment in Canada?
(3) Does Tellco Inc. have a withholding requirement for Canadian employees?

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Introduction To Federal Income Taxation In Canada 2016-2017

ISBN: 9781554968725

37th Edition

Authors: Robert E. Beam, Stanley N. Laiken, James J. Barnett

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