2 January 2003 Internal T.I. 2002-0162287 - Fixed base in Canada -- summary under Article 14

Although the non-resident taxpayer came to Canada on a recurring basis to perform the same or similar business activities (in respect of supervising the activities of independent contractors who sold financial products) and such activities were carried on at the same locations across Canada on a yearly basis, he did not have a fixed base in Canada because his visits to the various locations did not necessarily occur at the same spot, he did not spend more than a few days in each of the locations, he did not have physical control of the places where he worked and none of the premises could be identified with his business.