Avotus Corporation v. The Queen, 2007 DTC 215, 2006 TCC 505 -- summary under Agency

The proper interpretation of the agency agreement between the taxpayer, a Canadian-resident corporation, and its Puerto Rican subsidiary, was that the subsidiary was the taxpayer's agent for carrying on business in Puerto Rico with respect to the start-up period of the business. Given that there was no ambiguity in the agreement, it was not necessary to consider any extrinsic evidence of the parties' intention, and the fact that the Puerto Rican subsidiary represented in its tax returns to the Puerto Rican authorities that it was carrying on the business itself did not alter this conclusion.