| June 23, 1989 | |
| TO: Tax Reform and T1 Processing | FROM: Specialty Rulings |
| Division | Directorate |
| K.B. Harding | |
| Mr. K. Hillier | 957-2129 |
As a result of a conversation with G. McIntyre concerning the withholding of tax by non-resident with respect to salaries, wages, commissions etc. paid to residents of Canada, he suggested I forward a copy of our letter to your Division since we disagree with the attached May 11, 1978 letter signed by Mr. Howard Fisher.
While it is agreed that it may be impossible to force non-resident employers to comply with our law when they do not have a permanent establishment in Canada, we do not suggest that we should advise them to ignore the law since most non-residents will comply with our laws in order to carry on business in Canada.
We trust you will review this matter and, if necessary, advise the relevant law firm of our policy in this matter.
for DirectorReorganizations and Non-Resident DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch