MacIsaac v. The Queen, 2010 TCC 436 -- summary under Subsection 122.3(1)

The taxpayer supplied personnel for ships, oil rigs, and other offshore businesses. Applying Dunbar (2005 TCC 269 , 2005 DTC 1807), Webb J. found that the taxpayer's provision to its workers of health benefits, injury insurance, and payroll, and its continuing contact with the employees during their work terms, suggested that the taxpayer's business was not mere placement of employees, but amounted to supplying drilling services. The taxpayer therefore carried on business outside of Canada for purposes of s. 122.3(1).