Did this Engineer Have a Permanent Establishment in Canada?
Appellant Fails to Prove Timing of Revenues for Canada/US Treaty Purposes Wolf v. Canada 2019 FCA 283 Access Wolf Decision Here Background This decision raises an interesting treaty-related issue. The Appellant is an aerospace engineer. He was a US resident in 2012 but worked in Canada for over 183 days in that year. In 2012, the Appellant
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