No Plans To Extend COVID-Relief For Corporate Residency Determinations: CRA

COVID-19 Relief - Highly Affected Sectors Credit Availability Program (HASCAP) Guarantee

The Canada Revenue Agency (CRA) has indicated that it will not be extending its guidance concerning the impact of travel restrictions on corporate residency determinations. In 2020, the CRA issued guidance concerning international income tax issues in light of COVID-19 travel restrictions. The guidance indicated that, as of March 16, 2020, when determining cases of potential dual corporate residency, the CRA will not consider a corporation to have its place of effective management in Canada solely for the reason that a director of a corporation must participate in board meetings from Canada because of travel restrictions. This guidance applies to corporations covered by an income tax treaty that looks to the corporation's place of effective management as a residency tiebreaker.