With respect to Canadian income tax on non-residents, which of the following statements is NOT correct? Ignore any tax treaty implications.

A.

Non-residents must pay income tax in Canada with respect to capital gains arising on dispositions of any Canadian property including shares of Canadian companies.

B.

Non-residents must pay income tax in Canada on business profits from carrying on a business in Canada.

C.

Non-residents must pay income tax in Canada on capital gains resulting from the sale of real property (e.g. land and buildings) situated in Canada.

D.

Non-residents must pay income tax in Canada on employment income earned in Canada.