Corporate income tax for BVI company with the directors

This is a multi-part message in MIME format.
---------------------- multipart/alternative attachment
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...
---------------------- multipart/alternative attachment--


Trackback URL for this entry:

No trackback comments for this entry.