This is a multi-part message in MIME format. ---------------------- multipart/alternative attachment QUESTION: I have a BVI company ( I am the sole shareholder) which is carrying on a = business of consultancy services around the world. But no consutltancy services are rendered in Canada except that meeting = of board of directors is held once half-yearly in Vancouver. All = directors are either Canadian citizens or Canadian tax resident My = question is:whether this BVI company will be subject to Canadian = corporate income tax? ----------------------------------------------------- david ingram replies: If you are a resident of Canada, the corporation is taxable in Canada. If the directors are in defacto control, ie., they truly make the = decisions, than the corporation is taxable in Canada because the control = is here. =20 I expect that you are the sole shareholder and live out of the country = but that significant funds have been loaned to you by the Canadians to = keep it going, etc. If this is the case, the mind and control would = make it a resident of Canada for Canadian Income Tax purposes. You could, of course do the Denny's board meeting. Denny's restaurant in = Blaine, Washington is a very popular place for people in your position = to call a board meeting. All the Canadians trot (or drive) across the = border and have the OFFSHORE board meeting in the USA. =20 There is an exception to paying the Canadian tax if there are five full = time employees who are not related to you, the shareholder. I need more information to give a positive and specific answer, this was = a generality. ---------------------- multipart/alternative attachment An HTML attachment was scrubbed... URL: http://www.centa.com/CEN-TAPEDE/centapede/attachments/6c54ec6f/attachment.htm ---------------------- multipart/alternative attachment--
