https://www.taxtmi.com/caselaws?id=275213 A company was treated as a Canadian debtor for withholding purposes where residence, not nationality, governed the statutory expression; because its business, control, meetings, and dividend-generating income were in Canada, the withholding duty applied. The statutory obligation to deduct and remit tax was held mandatory, and uncertainty about whether a ministerial receipt would operate as a defence in every foreign forum did not excuse compliance. The tax on non-resident shareholders was also upheld as intra vires, as Parliament had authority to legislate for taxation even with extra-territorial effect. The taxing and withholding provisions were therefore valid in their application. en-us Wed, 31 Jul 1946 00:00:00 +0530 Sat, 22 Sep 2018 11:20:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=275213 A company was treated as a Canadian debtor for withholding purposes where residence, not nationality, governed the statutory expression; because its business, control, meetings, and dividend-generating income were in Canada, the withholding duty applied. The statutory obligation to deduct and remit tax was held mandatory, and uncertainty about whether a ministerial receipt would operate as a defence in every foreign forum did not excuse compliance. The tax on non-resident shareholders was also upheld as intra vires, as Parliament had authority to legislate for taxation even with extra-territorial effect. The taxing and withholding provisions were therefore valid in their application. Case-Laws Income Tax Wed, 31 Jul 1946 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=275213