Regarding whether USco (a US C-Corp and a “qualifying person” for purposes of the Canada-US Treaty) would be considered to be carrying on business in Canada by virtue only of some of its employees being Canadian residents who worked from their homes for two or three days a week, CRA noted:
Paragraph 253(b) of the Act may be engaged if the employee “solicits orders or offers anything for sale in Canada”, which generally includes actively seeking and attempting to obtain customers in Canada, beyond “a mere invitation to treat” or advertisement.