Maya Forestales S.A. c. La Reine, 2005 DTC 514, 2005 TCC 66, aff'd 2008 DTC 6100, 2006 FCA 35 -- summary under Paragraph 253(b)

The taxpayer was found to be carrying on business in Canada on the basis that through a Canadian mandatary it offered for sale, in Canada, Costa Rican plantation lots and solicited orders for services to be provided by it in connection with the sold lots, with each investor paying an overall amount in connection with the transactions which constituted an "indivisible whole" (p. 519). Although s. 115(1)(a)(ii) required a reasonable allocation of revenue and deductions, the Minister had assessed on the basis that all the revenues and expenses were applicable to Canada, and the appellant had provided no evidence of any kind whatsoever that would permit the allocation of a portion of the revenues and expenses to Costa Rica.