Before finding that film revenues of the U.S. taxpayer were reasonably attributable to its Canadian distributorship business notwithstanding they were also attributable to U.S. movie production, so that they would be exempted under Reg. 805 from Part XIII tax, Addy J stated:
Its film distribution activities and the advertising activities and public relations promotions connected with them are the equivalent of the sales and the sales promotion activities of a manufacturer who produces goods for sale. The distribution of the product results in the generation of income and profits which of course is the ultimate goal of the entire undertaking. ... Therefore, this is not the case of a US firm being engaged in business dealings in Canada, promoted, controlled and carried out entirely from the United States without a branch or organization in Canada.
And further stated:
The fact that a company chooses to have certain of its business activities carried out by agents does not of itself prevent those activities from being the business operations of the company.
See summary under Reg. 805.