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QUESTION:
Can you please explain what "Mind & Management " means in the context of a
Canadian Corporation which is a subsidiary company of a US head office
company ?
Are all decisions to be generally made by management in Canada with input
from the US head office for this to be true ?
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david ingram replies:
The residence of a corporation is generally where its management resides. However, no matter where the mind and management resides, all corporations incorporated in Canada after 27th April 1965 are resident in Canada for tax purposes.
I do not understand your question however. For Canadian purposes, mind and management is usually used to determine if a :Residence of a corporation normally is where its management resides. However, all corporations incorporated in Canada after 27th April 1965 are resident in Canada for tax purposes, regardless as to where the mind and management resides.
I do not understand your question however. Mind and Management is usually used by the Canadian government to make a foreign company (usually in a tax free country) taxable in Canada. In your case the Canadian sub is automatically taxable in Canada because it is incorporated in Canada
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