After indicating that the participation in Canadian board meetings by telephone from outside Canada would generally not constitute the exercise of the office in Canada for purposes of s. 115(1)(a)(i), the Directorate went on to summarize Reg. 104(2), and then stated:
Thus, in accordance with those rules, directors' fees received by a non-resident director, who has not ceased to reside in Canada in the year or in a previous year, and who holds an office or employment outside Canada, should generally not be subject to withholding tax under Regulation 102.