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The location of the meetings of the board of directors is not the only criterion to be considered in determining the location of the central management and control; it is only one element. The CRA may conclude that a company is resident in Canada when the actual management and control takes place in Canada, even if the meetings of the board of directors have taken place elsewhere. If a potential dual residency issue for a corporation involves a country with which Canada has not signed any tax treaties, residency status will be determined on a case-by-case basis.
If the circumstances warrant, the CRA will consider adopting a similar approach to determine the residency status of a commercial trust. This administrative approach will also be adopted where other entities, incorporated in foreign jurisdictions, are considered corporations for the purposes of Canadian tax law, such as limited liability companies.
Where a non-resident is resident in a country with which Canada does not have a tax treaty, that non-resident must file a return if it carries on business in Canada.