In the context of a general discussion of consequences where there was an acquisition of control of a corporation incorporated in Canada in 2005, but with a shift of its sales and administrative functions to a non-resident location, CRA indicated that even if its central management and control had moved to outside Canada, it would continue to be deemed by s. 250(4) to be resident in Canada, unless by virtue of an applicable tax treaty it was deemed to not be resident by virtue of s. 250(5). CRA also noted:
A non-resident corporation would be required to file a T2 return even if it claimed an exemption from Canadian tax under a tax treaty on all profits and gains.