9 February 2012 External T.I. 2008-0280941E5 F - Foreign sourced income - transportation -- summary under Paragraph 2(3)(b)

In the course of a general discussion of s. 4(1)(b), CRA stated:

If a taxpayer's business activities in a foreign country are incidental to its Canadian business, it may be reasonable to consider that the taxpayer is not carrying on business in the foreign country.