5 October 2012 Roundtable, 2012-0451241C6 F - Benefit conferred on a NR shareholder by a NR corp -- summary under Subsection 15(7)

In the course of finding that the gratuitous use by the non-resident shareholder of a Canadian property of the non-resident corporation likely produced a s. 214(3)(a) deemed dividend that was subject to Part XIII tax under s. 212(2), CRA noted:

[S]ubsection 15(7) makes subsection 15(1) applicable whether or not the corporation has been resident in Canada or has carried on a business there.