Which of the following BEST describes the general nature of acorporation's residence?

Choose the correct answer.

A.

Whether or not a company is a Canadian resident is easily determined by applying the rules within the ITA.

B.

Residence is primarily determined based on the country of incorporation and which country the corporation desires to be a resident of.

C.

Residence is primarily determined based on tax treaties that exist among countries within which a corporation does business.

D.

Residence is a subjective test based on the particulars of acorporation's operations, and is not easily manipulated.