Kinguk Trawl Inc. v. Canada, 2003 DTC 5168, 2003 FCA 85 -- summary under Clause 212(1)(b)(iii)(E)

The taxpayer (which was engaged in fishing for shrimp in Canadian waters) was found, based on the wording of an agreement between it and a non-resident group ("Uhrenholt") to have sold the shrimp harvested by it overseas through Uhrenholt as its agent rather than immediately upon landing, with the result that a portion of the interest credited by the taxpayer to Uhrenholt qualified for exemption under s. 212(1)(b)(iii)(E), as such interest related to business carried on by the taxpayer outside Canada (namely "the whole of the sales function, from the marketing of the catch to the making of the contracts"). Selling the catch was not merely an ancillary activity but an essential component of the taxpayer's business.